hcats draft request for proposal (drfp) q&a - hcats_draft... · question answer category /...

Question Answer Category / Topic

If the offeror possesses a Top Secret Facility Clearance, can they claim the points for

Secret and Top Secret since they exceed the 'Secret' Facility Clearance level

requirements?

This scoring element will be removed. Accreditation

Will the government also accept the Associate Certified Coach (ACC) certification for

HCaTS key personnel?

We have removed the Contractor Key Personnel scoring element

due to Industry Feedback. The final RFP will only have company-

wide accreditations.

Accreditation

Additional points are awarded for several certifications that are relevant to the

performance of HCaTS related services (ISO 9001, CMMI, etc), but the sustainability

certification isn't relevant to the offerors ability to effectively perform human capital

and training services. Can the government explain how sustainability certification is

relevant to an offerors ability to perform services under the HCaTS contract?

The HCaTS PMO has removed ISO 14001:2004 as an

accreditation and it will not appear in the final RFP.

Accreditation

Many training & learning professionals have degrees that are not specifically in

"Instructional Systems Design" but are focused on design & development of learning

experiences for adult learners. Will the government accpet alternative degrees in

areas such as: Education, Adult Learning, Instructional Technology, or Adult

Education / Training & Development?




Accreditation

Many human capital and training experts have degrees in releavnt fields that are not

specifically identified as human resources or human capital. Will the government

accept degrees in disciplines such as: Industrial/Organizational Psychology,

Organization Development, Management, or Business Mangement/Administration?




Accreditation

P.53, Section H.6.1 Question: Please confirm whether or not the small business must

have a recent DCAA audit. Specifically, being audited is outside the control of a

(small) business as it’s the government’s decision who and when to audit, and many

small firms have never received an audit. Our accounting system (Deltek) is capable

of being fully compliant with DCAA’s requirements for an acceptable accounting

system. Please confirm if the government is requiring small businesses that bid on

this effort to have had an audit prior as a condition of bidding on (or being awarded

this) IDIQ or if either of the following would be acceptable: (1) An outside firm

conducts an audit of the potential awardee following the same audit requirements as

DCAA and presents a determination of findings to the government, or (2) The

government notifies DCAA to come in and audit those businesses without audits prior

to making a final award.

All Offerors that are considered for award based on being in the

Top 40 proposals per Pool will have the option to have their

accounting system audited by DCAA. If an Offeror has an

accounting system that was audited by the DCAA within the last

three years and there have been no changes, their system will not

need to be audited again. Only Offerors with audited accounting

systems will be able to compete for cost-reimburseable type work at

the task order level.

Accreditation

H.6.5 EVMS is primarily used on large production contracts. Since this contract is

focused on HCaTS, it is not reasonable to use attainment of EVMS certification as a

discriminator. Recommend elimination of EVMS as a scoring factor.

Although the FAR requires the use of EVMS in major acquisitions

for IT/systems development, there may be task orders issued under

HCaTS that can benefit from EVMS, especially under KSA 3.

Accreditation

Please note: All information is subject to change. We are sharing this information now for transparency. Please continue to check the HCaTS interact blog for additoinal updates

HCaTS Draft Request for Proposal (DRFP) Q&A

Tuesday, May 19, 2015

1

H.6.5 The use of commercially integrated EVMS systems, such as DELTEK’s EVMS

module, provide similar benefits as a self-administered ANSI/EIA Standard-748

certified system. Will the HCaTS team consider commercially integrated business

system EVMS tools, such as Deltek’s ERP EVMS module, for points under L.5.4.4?

No Accreditation

H.6.8 ISO 14001:2004 specifically allows for self-certification. Companies working

with the certification, therefore, may or may not have a 3rd party providing

independent validation of the use of these processes and yet this may make a

difference in scoring. Recommend acceptance of self-certification or removing this

certification from the scoring evaluation.

This Accreditation has been removed. Accreditation

H.6.2-5: We recommend removing the award of additional points for the possession

of audited estimating and purchasing systems as well as forward pricing rates

agreements (FPRA), forward pricing rate recommendations (FPRP), and approved

billing rates. We appreciate that the HCaTS PMO is not considering these as

mandatory or minimum requirements; however, Offerors who have met these criteria

should not be considered more favorably. These additional equirements are

applicable to cost reimbursable contracts and have no bearing on the ability of

Offerors to successfully deliver on other types of contracts. We understand that the

HCaTS PMO is seeking to identify objective evaluation criteria by which to

differentiate contractors, but we do not believe these are objective criteria that

demonstrate the quality of the service being provided. These additional criteria will

bias the selection of contractors based upon criteria that do not relate to value

provided to the government for non-cost-reimbursable contract types. We propose

that the HCaTS PMO categorize contractors based on cost accounting standards

criteria; but do not limit those contractors that do not intend to bid on cost-

reimbursable from being eligible for award.

This recommendation was considered but the RFP will not be

amended.

Accreditation

H.6.1: We recommend removing the requirement that Offerors possess a DCAA-

audited accounting system. This mandatory requirement may disqualify Offerors with

strong relevant capabilities from participating and reduce competition at the task

order level. We recognize that there are instances in which Cost Plus contracts are

necessary and that a certified accounting system supports these contracts, but a

large number of task orders issued under HCaTS will not fit under this description and

are likely to be firm fixed price. There are also challenges associated with cost

reimbursable contracts, such as added administrative costs and constrained access

to an Offeror’s full complement of services. As a result, we recommend only requiring

cost reimbursable contract pricing at the task order level, when necessary. Cost

reimbursable contract pricing could become a feature of the IDIQ contract, but not a

requirement or evaluation criterion. We propose that HCaTS PMO categorize

contractors based on cost accounting standards criteria; but do not limit those

contractors that do not intend to bid on cost-reimbursable from being eligible for

award. This approach will provide contracting agencies the flexibility of when (and

when not) to require cost reimbursable contract pricing, while expanding competition.

This recommendation was considered. Accreditation

2

L.5.4.3 Credit is applied for the scoring element of Forward Pricing Rate

Agreements (FPRA), Forward Pricing Rate Recommendations (FPRR), and/or

Approved Billing, if applicable. This element, however, is not scored evenly. There

are more points awarded for FPRAs vs. FPRRs - and further based on time of

approval (even points for expired FPRAs or expired Approved Billing Rates). It is

requested that GSA reconsider this methodology and award one set of points for any

current FPRA, FPRR, and/or Approved Billing Rates. This would be fair and

consistent with the methodology of scoring under OASIS.

We will revisit the allocation of points for each scoring element. Accreditation

section H.7 “Cost Accounting Standards”: Per 48 CR 9903.201-1, CAS is not

required for Firm Fixed Price or commercial item acquisitions; both of which will be

allowable under the HCATS contract vehicle per the RFP at page 5 section B.1.6

“Contract Type”. The Excel document J.7 Cost-Price Worksheet is set up to

exclusively display cost-reimbursement pricing elements (direct labor, fringe, G&A,

overhead, profit, etc.) and does not provide a section for offerors to display FFP

labor rates. Additionally, the RFP instructs offerors that they are not allowed to modify

the pricing template. How shall offerors who are exempt from having an DCAA-

approved CAS system propose their FFP rates?

The labor rates awarded under HCaTS will be awarded as Fixed

Price with Economic Price Adjustment (FP EPA), to be referenced

only when a sole-sourced Time-and-Materials task order is issued.

To ensure the labor rates are fair and reasonable and the Offeror is

complying with its accounting system, Attachment J.7 requires of

Offerors to breakdown their cost elements that make up the fully

burdened rate per labor category.

Accreditation

L.4.1, L.5.4.1: Should the offeror submit two separate documents since the

requirement in L.5.4.1 is to submit an official audit report and to provide POC

information and reference page and paragraph of the audit? This requirement

conflicts with the Proposal Format Table. The table indicates that the page limit is

limited to the audit only. If the offeror is to submit two separate documents, what

naming convention should be used for the second document?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

L.4.1, L.5.4.2 Should the offeror submit two separate documents since the








Accreditation

L.4.1 and L.5.4.3 Should the offeror submit separate documents since the





naming convention should be used for the second document for the FPRA, FPRR,

and Approved Billing Rates?



Accreditation









Accreditation

3


requirement in L.5.4.5 is to submit a certification and to provide POC information and

reference page and paragraph of the certification? This requirement conflicts with the

Proposal Format Table. The table indicates that the page limit is limited to the

certification only. If the offeror is to submit two separate documents, what naming

convention should be used for the second document?



Accreditation









Accreditation

L.4.1, L.5.4, 7 Should the offeror submit two separate documents since the








Accreditation

We are a current small business TMA contractor and have been performing training

and human capital studies for over 17 years. We have never once needed many of

the certifications called for in the solicitation (e.g., ISO, CMMI, EVS). We believe

there is the danger, that having these certifications in the scoring system could skew

the outcomes in unanticipated ways. For example, it may be that small business IT

firms that do some human capital and training projects on the side would score higher

than true training and human capital firms. We request you eliminate these

certifications (or further reduce their point count).

We have removed the ISO 14001 and CMMI certifications and the

Contractor Key Personnel scoring element due to Industry

Feedback.

Accreditation

The current requirements and evaluation criteria outlined for vendors to compete on

the small business vehicle significantly impact the number of qualified vendors to

support this human capital requirement. Moreover, the evaluation criteria are hyper-

focused on operational processes (e.g., EVM, estimating systems) rather than on the

core of what the Government is interested in—quality of services to customers.

Based on the current requirements, it is questionable as to whether the Government

will get the most qualified pool of small businesses. It is our recommendation that the

Government consider removing these additional process-centric evaluation criteria for

the HCaTS SB vehicle and rather focus on criteria that evaluate the vendors’ ability to

successfully deliver goods and services to the Government.

We have removed the ISO 14001 and CMMI certifications and the

Contractor Key Personnel scoring element due to Industry

Feedback.

Accreditation

4

C.3.3 Given that IT is considered an ancillary support service or product on HCaTS

task orders, will the Government remove additional scoring points for EVMS?

Justification/Reason/Explanation: The FAR only requires the use of EVMS in major

acquisitions for IT/systems development. Similarly, OPM-specific guidance requires

EVMS in major acquisitions for IT development. IT and system

development/maintenance are ancillary services under HCaTS. Federal EVMS

compliance accreditation is limited, by the government, to contractors supporting

major programs. Contractors specializing in human capital and training solutions are

unlikely to have accredited EVMS and therefore will be penalized relative to large

system integrators that also happen to provide HC and TS.




Accreditation

L.5.4.7 ISO 14001:2004 specifies the requirements of an environmental

management system (EMS). The registration/certification process is costly and can

take several years. Will the government remove additional scoring points for ISO

14001:2004? Justification/Reason/Explanation: Contractors specializing in human

capital and training solutions are unlikely to have accredited EMS and therefore will

be penalized relative to large system integrators, manufactures and ther suppliers

that also happen to provide Human Capital and Training services.

This accreditation will be removed from the RFP. Accreditation

H.6.1-3 The Department of Defense (DOD) has established business system criteria

in the DOD Federal Acquisition Regulation Supplement (DFARS), see DFARS

252.242-7005. In accordance with the DFARS requirements, the adequacy of

contractor business systems is determined by the cognizant Administrative

Contracting Officer (ACO). Will GSA accept DOD ACO determinations of business

system adequacy in lieu of DCAA audit results?

Yes, a Cognizant Federal Agency auditing any accreditation with

the exception of the Accounting System is allowed.

Accreditation

H.6.1-3 In many cases, DCAA has never audited a contractor’s accounting system. If

DCAA has never audited the contractor’s accounting system is the contractor

ineligible for award under the HCATS program? Would a DCMA ACO determination

of adequacy suffice in lieu of a DCAA audit?









Accreditation

H.6.4 The creation and change of FPRA, FPRR, PBR and/or Approved Billing Rates

is frequently the result of negotiation with the cognizant ACO. If there is no audit

report, is there a specific submission requirement for some other type of information

or will a contractor explanation of the change be sufficient?

The RFP will be amended to allow for a CFA's Contracting Officer's

determination as verification. It will also be amended to state that

the FPRA, FPRR, and Approved Billing Rates shall bave be current

and audited/determined acceptable within the last three years.

Accreditation

Does the Government have performance data that demonstrates that a company

having ISO certification or a CMMI rating performs better than companies that do not

have ISO certification or CMMI rating?

The CMMI Certification will be removed from the RFP. There will

also be changes to the ISO accreditations that are scoring

elements. These were determined based on reseach and industry

feedback.

Accreditation

5

How will the Government verify that the division/organization/group within the

company that submits a proposal stating that they are ISO certified are actually the

division/organization/group that will be performing the work?

The Offeror shall submit enough verifiable information to

substantiate the division/organization/group that is submitting the

proposal is the one that has the certification. The HCaTS PMO will

audit contracts and reach out to Ordering Contracting Officers to

verify that the Contractor is performing in accordance with its

contract.

Accreditation

What is the value of an Earned Value Management Systems in the Size Standard for

small businesses under $11 million (Pool 1)?

The HCaTS PMO chose accreditations based on their value for

work that may be performed and not based on size standard.

Accreditation

Will the Government consider providing credit for accreditations such as IACET,

whereby Offerors have undergone a rigorous third-party review and have met the

nationally-recognized standards set forth by ANSI and IACET to ensure high quality

continuing education and training programs for adult learners? IACET is the

premier standard-setting organization for the continuing education and training

industry, and is an accredited Standards Developing Organization (SDO) by the

American National Standards Institute (ANSI). Accreditation by ANSI signifies that

IACET’s procedures meet the Institute’s essential requirements for openness,

balance, consensus, and due process.

Several large, Federal training institutions are also accredited by IACET, to include,

but not limited to FEMA’s Emergency Management Institute, the Defense Acquisition

University, and the Federal Deposit Insurance Corporation’s Corporate University.

This accreditation was previously under consideration and was

determined not to be included in the RFP.

Accreditation

ISO 14001 was designed for manufacturers to demonstrate how they protect the

environment. Given this is a services-only vehicle can the government explain why

application of this standard is relevant (adds points to the evaluation) and how the

government intends to apply it post award?

This accreditation has been removed from the final RFP. Accreditation

When the government requires proof of ISO certification it becomes a cost-

reimbursable line item on a contract. Will the government in fact reimburse

companies for this certification or consider removing/modifying the ISO requirement

to state “company certifies that it follows ISO policies and procedures?

No, requiring proof of an ISO certification does not make it a cost-

reimbursable line item on a contract. Offerors are eligible for

additional points if they have an ISO certification, but are prohibited

from passing any costs associated with obtaining or maintaining it

at the contract level. Depending on the Offeror's accounting

system and if the task order permits it, they may be able to pass on

the cost at the task order level.

Accreditation

6

References from C.3.3., M.7: L.5.4.4; L.5.4.5; L.5.4.6; L.5.4.4.7; L.5.4.9

Discussion. C.3.3. states that, “IT is considered ancillary support service or product

on task orders and may be performed and/or provided only when the service or

product is integral and necessary to complete a total integrated solution under a

professional service based requirement within the scope of HCaTS.” Yet, the CMMI,

ISO, and EVMS requirement are so common to the Federal IT community that even

small and disadvantaged set-aside IDIQs require them of the

prime. Therefore, these requirements simply serve as barriers to entry for mid-to

large HR/HCM companies who do not provide IT professional services. Conversely,

any IT company small or large would be able to obtain substantial points for holding

these certifications and accreditations regardless of their corporate investment,

commitment, and experience in the HR/HCM vertical that is the purpose of HCaTS.

Suggestion. Eliminate the EVMS ANSI/EIA, CMMI, and ISO certifications and instead

allow them to be included as necessary at the TO level as necessary. Since IT is

ancillary to HCaTS, these certifications and accreditations will likely be irrelevant to

the majority of HCaTS task orders.

The CMMI and ISO 14001 Certification will be removed from the

RFP. There will also be changes to the ISO accreditations that are

scoring elements. These were determined based on reseach and

industry feedback.

Accreditation

F.5 Performance Standards reads . . . . “The Contractor shall maintain throughout the

ordering period of HCaTS, at a minimum, the accreditations at time of contract award.

For example, if a Contractor’s proposal included an acceptable accounting system

and ISO 9001:2008 certification and made a part of contract award, then the

Contractor shall maintain an acceptable accounting system and ISO 9001:2008

certification for the duration of the HCaTS ordering period.”

However, as the industry evolves, certain certifications are replaced or superseded

by new certifications. Maintaining a certification in these cases may, in fact, not be in

the best interest of the government. We recommend the statement be reworded

accordingly . . . “The Contractor shall maintain or exceed throughout the ordering

period of HCaTS, at a minimum, the accreditations at time of contract award.”

The RFP will be amended to reflect your recommendation. Accreditation

M.7, F.5 Performance Standards reads . . . .“An acceptable accounting system is

mandatory for all Contractors. Compliance with the Cost Accounting Standards (CAS)

are mandatory unless covered by exemption under 48 CFR 9903.201-1 and 48 CFR

9903.201-2. All other accreditations (i.e., certifications, clearances, systems) are

optional;”

We agree with the government’s approach as stated. However, we feel it is

contradictory for the government to award evaluation points for optional systems and

accreditations when many of these systems can’t be certified by DCAA unless the

government mandates them. DCAA only approves them only on an as needed basis.

We suggest the government not award evaluation points for these optional

certifications and systems.




We will keep the optional organizational accreditations but will

revisit the allocation of points for each scoring element.

Accreditation

7

H.6.2 – H.6.8, M.7 In Section H of the RFP, there are numerous certifications that

offerors are “encouraged” to have. These include things such as an acceptable

estimating and purchasing system, forward pricing rate agreements, EVMS, CMMI

Level 3, ISO 9001:2008 and 14001:2004, etc. For the most part, these certifications

are not relevant to training and human capital development contracts. In fact, in our

25 year history, completing over 8,000 training and human capital task orders, these

certifications/systems have never been required.

The certifications listed are far more applicable to Information Technology hardware

and services contracts. Therefore, companies that hold these certifications are more

likely to be systems integrators, and not companies that specialize in the work being

procured under this contract vehicle. Although these certifications are not mandatory,

additional evaluation points are assigned for having them. This will put companies

specializing in human capital and training development at a disadvantage; this seems

contrary to what OPM would want and what would be in the best interest of this

contract. We suggest that GSA remove the certifications that are encouraged in

H.6.2 – H.6.8 and request that such certifications, if deemed necessary in the future,

can be requested at the task order level.

We have removed the Contractor Key Personnel and ISO 14001

Certification scoring element due to Industry Feedback. The final

RFP will only have company-wide accreditations.

We will keep the optional organizational accreditations but will


Accreditation

Section H.6, Accreditations, and Section H.6.1, Acceptable Accounting System. Many

small businesses, especially 8(a) businesses, have not yet undergone DCAA

compliance audits of their accounting systems. Therefore, to demonstrate that a

HCaTS SB Contractor maintains an “acceptable accounting system,” how will the

determination of “acceptable” status be rendered? Is it adequate for the Contractor to

possess an accounting system that is listed on the HCaTS Program Management

Office (PMO) master list of acceptable accounting platforms/software systems? Or,

alternatively, will each HCaTS SB Contractor be required to submit a statement self-

certifying the fact their company possesses an acceptable accounting system? Is self-

certification of an acceptable accounting system the purpose of the attached form

“J.3, Modified Pre-Award Survey: SF 1408”? How will the acceptability of the

accounting system be validated by the PMO and/or OCO? The text in these sections

is unclear.









Accreditation

Sections L.5.4.6 and L.5.4.7 (Page 127) outline scoring elements for ISO 9001:2008

and ISO 14001:2004 certifications. These certifications are heavily focused on

product development and are significantly less relevant to service-oriented industries.

Specifically, these certifications are virtually never required for human capital and

training tasks. Will GSA consider removing these certification from consideration?

ISO 14001:2004 will be removed from the RFP Accreditation

8

Systems and Certifications

We recommend that GSA reevaluate the systems and certifications included in the

DRFP to ensure that they are relevant to contract performance under the future

HCaTS vehicle. There are some included in the current draft that are not applicable

to HCaTS type work, such as Earned Value Management System and ISO14001

certification for Environmental Management Systems. Rather than including them in

the scoring at the master contract level and putting capable offerors that do not have

these accreditations at a disadvantage, it would be more appropriate to allow

agencies the option of requiring them at the task order level. Further, in order to

maximize competition, systems and certifications that are necessary to the

performance of the contract should be considered matters of contract administration.

They should not be evaluated subjectively for extra points during the final evaluation

for award

The HCaTS Team has removed the Contractor Key Personnel

scoring element due to Industry Feedback. The final RFP will only

have company-wide accreditations.

In addition, ISO 14001 and the CMMI certification have been

removed.

Accreditation

FPRA/FPRR/Approved billing rates—Credit is applied for Forward Pricing Rate

Agreements (FPRA), Forward Pricing Rate Recommendations (FPRR), and/or

Approved Billing, if applicable. However, these items are not scored equally. There

are more points awarded for FPRAs vs. FPRRs - and further based on time of

approval (for expired FPRAs or expired Approved Billing Rates). We recommend that

GSA award one set of points for any current FPRA, FPRR, and/or Approved Billing

Rates.

We have removed expired FPRAs as a scoring element. Since

FPRAs are actual agreements, as oppose to an FPRR, which are

just recommendations, we believe the FPRA have additional value.

Accreditation

Comment: In sections L.5.4, the Government includes scoring elements for EVMS

ANSI/EIA Standard 748, CMMI Capability Level 3, MCCI Maturity Level I, and ISO

certifications. These certifications are most commonly beneficial to and required in

the Information Technology (IT) field. They are cost prohibitive for cost conscious,

medium sized companies that specialize in Human Resources and Human Capital

Management (HR/HCM).

Recommendation: We recommend removal of these certifications as scoring

elements as they do not reflect the potential success of a prime contractor on

HR/HCM type work.

The CMMI certification will be removed from the RFP. Accreditation

9

129 of the RFP: L.5.4.1 Acceptable Estimating System, L.5.4.2 Acceptable

Purchasing System, L.5.4.3 FFRA, L.5.4.4 EVMS Will the government confirm that a

small business, if tied to a large business or other entity, may NOT use the other

entity’s systems as if it were their own for points?

Within a corporate structure, an Offeror may utilize resources from

a parent company, affiliate, division, and/or subsidiary provided that

the meaningful relationship was in place at the time the contract or

task order being submitted as a Relevant Experience Project was

performed. The Government shall allow an Offeror to take credit

for any evaluation element, including Relevant Experience

Project(s), accreditations from a parent company, affiliate, division,

and/or subsidiary as long as there is a meaningful relationship to

the Offeror and commitment letters are provided to the

Government.

Affiliates are business concerns that are affiliates of each other if,

directly or indirectly, either one controls or has the power to control

the other, or another concern controls or has the power to control

both.

Division is a separate business unit of a company representing a

specific business function.

Subsidiary means an entity in which more than fifty percent (50%)

of the entity is owned directly by a parent corporation; or through

another subsidiary of a parent corporation.

If none of the above are met, you cannot use their resources.

Accreditation

Section H.6.2, pg 51: Acceptable Estimating System

In our experience, an estimating system is required when there is a need for a

contractor to provide certified cost and pricing data as outlined in DFAR 215.408(2).

FAR 15.403-1 and DFAR 215.403-1 outline the prohibition on obtaining certified cost

or pricing data. The type of services outlined in the draft RFP are normally provided

as commercial services, and adequate price competition normally exists. Both are

scenarios where certified cost and pricing data would not be needed. As such, it is

unlikely that the majority of contracts issued under the HCaTS ID/IQ, would require

the need for a contractor estimating system. Even if a contractor has an estimating

system in place, it is our experience that unless that contractor possesses a

significant amount of contract awards in which certified cost and pricing data was

required, it is highly unlikely that their estimating system has been audited by DCAA,

DCMA, or any other Cognizant Federal Agency. Awarding bonus points for this

requirement disadvantages companies that mainly provide commercial services to the

federal government.

Q15. Would the Government consider removing the requirements outlined in H.6.2

titled Acceptable Estimating System?


amended.

Accreditation

10

Section H.6.3, pg 51: Acceptable Purchasing System

FAR 44.3 states that a contractors purchasing system review (CPSR) only be

conducted “If a contractor’s sales to the Government (excluding competitively

awarded firm-fixed-price and competitively awarded fixed-price with economic price

adjustment contracts and sales of commercial items pursuant to Part 12) are

expected to exceed $25 million during the next 12 months”. It is our experience that

the services that will be requested under this contract are normally procured as

commercial services, and will be awarded through the use of firm-fixed-price

contracts. Awarding bonus points for this requirement disadvantages companies that

mainly provide commercial services to the federal Government, and unless you meet

the requirements outlined in FAR 44.3, even if a contractor has a purchasing system

that would be deemed acceptable, that contractor has no control over their

purchasing system being audited under a CPSR.

Q16. Would the Government consider removing the requirements outlined in H.6.3

titled Acceptable Purchasing System?


amended.

Accreditation

For these optional systems – would the government consider accepting a third party

assessment? Or would the government make enough time for offerors to go through

a DCAA audit?

No, all optional accreditations shall have been received by the date

the RFP closes by a Government entity.

Accreditation

Question: Can the government provide further clarification to the following

requirement: The Contractor shall have and maintain an acceptable accounting

system that will permit timely development of all necessary cost data in the form

required by the proposed contract type. Does this require that the SB have a certified

DCAA compliant accounting system?









Accreditation

Credit for Earned Value Management Systems should be granted only at the task

order level, where it is clear whether and how EVMS is relevant and of value.

Consideration should also be given to aligning any EVMS requirement to the new

DoD guidance under which the EVMS threshold will be raised to $100 million.

This recommendation was considered and the RFP will not be

amended.

Accreditation

11

L.5.1.5. and H.6.1 We strongly recommend that the requirement to secure a future

DCAA audit not be a pass/fail requirement at the IDIQ level.

• The predecessor contract, TMA, successfully met agencies needs without

procuring cost reimbursable contracts, and the requirement at the IDIQ level is overly

restrictive for FFP and T&M Task Orders.

• It penalizes those firms whose core services directly relate to Pools 1 and 2,

such as firms who performed successfully under the TMA contract and new

competitors who successfully perform for many non-DoD federal agencies as well as

other industry sectors but have not required a DCAA audit in the past, while

inappropriately providing an advantage to those firms who perform Pool 1 and 2

services as an ancillary function, but have DCAA audits.

• Given the backlog and time to schedule and complete a DCAA audit, the

business case to pursue HCaTS without confidence of being able to compete for task

orders cannot be made which will result in significantly less competition for the

HCaTS vehicle and post award.

Offerors are not required to have an audited accounting system

prior to award. All Offerors that are considered for award based on

being in the Top 40 proposals per Pool will have the option to have

their accounting system audited by DCAA. If an Offeror has an






Accreditation

L.5.4.4 We recommend that the government remove the option to receive additional

points for an EVMS from the RFP for the following reasons:

• EVMS is required for major acquisitions for development, according to the FAR,

Subpart 34.2 and OMB Circular A-11

• With the elimination of major development work associated with the original

Pool 3 and exclusion of Learning Management Systems, the requirement for EVMS is

inconsistent with the FAR applicability and beyond the scope of Pools 1 and 2

• Companies who focus on Human Capital and Training services most often

would not seek or qualify for a DCMA audit of EVMS




Accreditation

L.5.4.5 With the elimination of the original Pool 3, we recommend modifying this

section of the RFP to only include CMMI Maturity Level 3 for Services. Many Training

and Human Capital consulting companies do not have CMMI in Development due to

the nature of work. Allowing CMMI in Development would give an advantage to those

firms who specialize in systems development.

This certification has been removed. Accreditation

Would the Government consider removing the mandate for Small Business

contractors to have an accounting system audited and found acceptable by DCAA

from the HCaTS SB RFP? This mandate is understood for the large business track,

however, most small businesses do not have audited accounting systems.

Small businesses are not required to have an audited accounting

system prior to award. All Offerors that are considered for award

based on being in the Top 40 proposals per Pool will have the

option to have their accounting system audited by DCAA. If an

Offeror has an accounting system that was audited by the DCAA

within the last three years and there have been no changes, their

system will not need to be audited again. Only Offerors with audited

accounting systems will be able to compete for cost-reimburseable

type work at the task order level.

Accreditation

12

1. Page 26 of 144 . . . F.5 Performance Standards reads . . . . The Contractor

shall maintain throughout the ordering period of HCaTS, at a minimum, the

accreditations at time of contract award. For example, if a Contractor’s proposal

included an acceptable accounting system and ISO 9001:2008 certification and made

a part of contract award, then the Contractor shall maintain an acceptable accounting

system and ISO 9001:2008 certification for the duration of the HCaTS ordering

period.

Comments/Suggestions: We recommend the statement be reworded accordingly . . .

“The Contractor shall maintain or exceed throughout the ordering period of HCaTS, at

a minimum, the accreditations at time of contract award. For example, if a

Contractor’s proposal included an acceptable accounting system and ISO 9001:2008

certification and made a part of contract award, then the Contractor shall maintain an

acceptable accounting system and ISO 9001:2008 certification for the duration of the

HCaTS ordering period.” As the industry evolves, certain certifications are replaced

or superseded by new certifications. Maintaining a certification in these cases may

not be in the best interest of the government.

The RFP will be revised to reflect equivalency for successor

certifications.

Accreditation

2. Page 26 of 144 . . . F.5 Performance Standards reads . . . .“An acceptable

accounting system is mandatory for all Contractors. Compliance with the Cost

Accounting Standards (CAS) are mandatory unless covered by exemption under 48

CFR 9903.201-1 and 48 CFR 9903.201-2. All other accreditations (i.e., certifications,

clearances, systems) are optional;”

Comments/Suggestions: While its reasonable to request compliance with CAS, it is

unreasonable for the government to award evaluation points for optional systems

when many of these systems can’t be certified by DCAA unless the government

requires them. In other words, they should be optional systems and the government

should not award evaluation points for them.

Your recommendation will be considered. Accreditation

7. Pages 51 and 52 of 144 . . . H.6.2 Acceptable Estimating System, H.6.3

Acceptable Purchasing System, H.6.4 Forward Pricing Rate Agreements, H.6.5

Earned Value Management Systems.

Comments/Suggestions: Training and Human Capital contracts are typically

procured through Firm-Fixed Price (FFP) competitive bids. Therefore, these systems

and Forward Pricing Rates are not needed. DCAA is the only body approving these

systems and they only approve on an as needed basis. Additionally, they don’t have

the capacity to certify these systems for every government contractor.

We recommend removing any and all points associated with these certifications, as

the government does not have the capacity to certify these systems.

Your recommendation will be considered. Accreditation

13

8. Page 53 of 144 . . . H.6.6 CMMI Level Certification

Comments/Suggestions: This certification is predominantly used in the

manufacturing industry. While CMMI can be a beneficial certification to achieve,

there has never been a requirement for CMMI for training and human capital

services.

We recommend lowering the certification level to II.

The CMMI certification will be removed from the RFP. Accreditation

9. Page 53 of 144 . . . H.6.8 ISO 14001:2004 Certification

Comments/Suggestions: This certification is irrelevant to this procurement. We

recommend removing it from the solicitation or downgrading to a minimum level.

This accredidation has been removed. Accreditation

Standard Form 1408 is labeled as 5 questions with sub-sections under each question

(e.g., 2(a)) - The solicitation states "offeror is not required to answer questions 3

through 21" - does this refer to numbers 2-5 with all subsections? Is there an SF1408

with 21 questions labeled 1-21? If so, can GSA provide a copy or a link for

contractors to access?

The final version of J.3 Pre-Award Survey will reflect the correct

information.

Attachments

REFERENCE: Draft Section J.10 NAICS Code Re-Determination Form; Page 1

OFFEROR COMMENT/QUESTION: Discussion: On April 3, 2015, the Government

issued Section J attachments to the Draft RFP which included Section J.10 “NAICS

Code Re-Determination Form.” This Form states: “Contracting Officers: You are

receiving this form because the Offeror cited in Section I claims that the majority of

the work performed on the contract or task order cited in

Section II-A falls within one of the NAICS codes listed in Section II-E, and not the

reported NAICS Code. The Human Capital and Training Solutions (HCaTS) team is

asking that you, as duly warranted Contracting Officer of the contract or task order

cited in Section II-A, certify that the scope of the contract or task order falls within one

of the NAICS codes in Section II-E, and not the reported NAICS Code.” The above

statement appears to be asking the Contracting Officer to make a re-determination of

the appropriate NAICS code for the work performed under the cited contract; an

action which is not legally permissible. By regulation, the contracting officer is

required to “determine the appropriate NAICS Code and related small business size

standard and include them in solicitations.” 48 C.F.R. (“FAR”) 19.303(a)(1). Thus, the

required time for determining the applicable NAICS Code is at the time of solicitation,

13 C.F.R. 121.402(b), not after contract award. The NAICS code assigned to a

procurement, and its corresponding size standard, is final unless timely appealed to

SBA's Office of Hearings and Appeals. FAR 19.303(c); 13 C.F.R. 121.402(d).

Question: Are you asking the Contracting Officer to make a determination to

CHANGE the NAICS from what was originally assigned?

Attachment J.10 NAICS Redetermination form will be amended in

the final RFP to state that this redetermination is solely for the

purposes of the evaluation of HCaTS and any redetermination will

not require of the Contracting Officer to take any action or make

any changes in the original contractual documents or how it was

reported in PPIRS and FPDS-NG.

Attachments

J. 7 The Cost-Price Worksheet instructs “Editing or reformatting this sheet in any

way is prohibited and will result in your worksheet not being reviewed”

Would the government allow the offeror to edit the Cost-Price Worksheet in order for

the offeror to comply with its accounting and estimating systems?

No, the Offeror must fit their cost elements into those provided into

J.7 Cost/Price Worksheet.

Attachments

14

J.5.2 and Section H.6.1 states “Only those Contractors that maintain an acceptable

accounting system, as approved by the HCaTS CO, shall be eligible for task order

solicitations.” In addition, the Attachment J.5.2, Self Scoring Work Sheet requires

contractors to state whether their accounting system has been audited. These

statements may lead the reader to believe that contractors that have not been audited

by DCAA may be barred from the award of task orders from this

RFP. Or it may simply mean that said contractors will need to have their systems

audited before an award can be made. Could the government please clarify this

requirement? Will the government request the DCAA conduct an accounting system

audit for those contractors that are not currently approved at the time of the

proposal? Will the government provide contractors the time to go through this

process with DCAA without penalty or discrimination?

All Offerors eligible and considered for award will have the option to

have their accounting system audited by DCAA. Only Offerors with

audited accounting systems will be able to compete for cost-

reimburseable type work at the task order level.

Attachments

L.5.1.2 Attachment J.2 (Proposal Checklist) seems to be missing from the posted

attachments. Can you please provide Attachment J.2 for Offerors to review?

The Final RFP will have this attachment included. Attachments

J.5.2 and L.5.2.1 Column F does not calculate beyond row 16. Instructions to offerors

on page 120 state that the sheet should auto-sum. Will the Government please

provide an updated copy of Attachment J.5.2 Self Scoring Worksheet SB Pool 2 in

which the auto-sum calculations are included?

The Self Scoring Worksheets (Attachments J.5.1 and J.5.2) were

released in draft form and will be fully functioning when released

with the RFP.

Attachments

L.5.2 This section states that “Additional instructions for filling out Relevant

Experience Projects Template is found in Section J.5.3 (Self Scoring Worksheet SB

(Sample)).” Attachment J.5.3 seems to be missing. Can you please provide

Attachment J.5.3 for Offerors to review?

This will be released with the RFP. Attachments

Attachment J7 states that “DCAA audited rates should be input” however the

solicitation does not indicate that a DCAA audit is required prior to submission. Will

the government clarify or remove the requirement for DCAA audit prior to

submission?









Attachments

Recommendation 4: Eliminate Estimating the Total Value of a KSA within J.5.1 and

J.5.2 Scoring Sheets

Within Attachments J.5.1 and J.5.2 there is a requirement to specify the total dollar

value of the KSA and the total percentage associated with a KSA. We do not believe

that this can be measured accurately nor do we believe that documentation exists

that would allow a company to do more than give a general estimate of that value.

Thus, the resulting value is neither objective nor reliable and can be whatever the

estimator thinks best serves their purpose -- and therefore should not be collected nor

evaluated.

This will be removed in the final RFP. Attachments

On the pre-award survey, Section III question 4 – Can you define “full operation”? Fully operational for a commercial accounting system means that

the Offerors accounting system is able to handle all contract types

and generating inputs and outputs, and all components of the

accounting systems are operational.

Attachments

15

On the pre-award survey, Section III – what information is required to “validate” an

answer in section 3?

Each question in Section III states what form of substantiation is

required for an affirmative response.

Attachments

The modified Pre-Award Survey Comment box has a limited field capacity (75

characters). Is this intentional?

This will be amended in the final RFP. Attachments

L.5.5 “The Offeror shall propose ceiling rates for T&M/L-H task orders by completing

Columns H through V of the Cost/Price Worksheet.” The Cost/Price Worksheets only

include Columns H through N. Please correct either spreadsheet or instructions.

The instructions will be amended in the final RFP. Attachments

J.3 Preaward Survey SF 1408 HCaTS v.01 The form, in its current state, cannot be

edited and the comment sections on the form aren’t large enough to accommodate

our responses. We suggest the government make the form editable and/or increase

the size of the comment sections so that we can enter sufficient responses.

The comment sizes will be increased in the final version. Attachments

J.6 Past Performance Substitute HCaTS v.01 The form, in its current state, requires

the contracting officer to admit to incorrectly assigning the original NAICS code. We

suggest that GSA change the form to allow the contracting officer to state what

NAICS code “could” have been selected rather than “should” have been selected.

The language in the final J.10 will be amended to state that the

NAICS Code determination is solely for evaluation purposes for

HCaTS and does not change any official contractual documents nor

reports.

Attachments

Attachments J.5.1 and J.5.2, Self Scoring Sheets. We recommend that the

requirement of the submission of the Self-Scoring sheets as a part of the proposal be

removed. Contractors cannot be impartial when scoring themselves, and will likely try

to apply various techniques and schemes to skew their point values upward,

exploiting any unintentional loopholes that might exist in the forms. The Self-Scoring

sheets seem like an extra paperwork burden of limited value, because all

respondents will be averse to rating themselves negatively, even when they are well

aware of their own weaknesses. The presence of such Self-Scoring sheets also

unintentionally implies that the proposal review staff lacks credibility or accuracy, and

therefore their assessments need to be cross-checked. This in turn could undermine

industry confidence in the review team and generate additional unforeseen problems.

The RFP states "in the event the Government discovers

misleading, falsified, and/or fraudulent Relevant Experience Project

information, documents, statements, and/or claimed points in

Section J.5.1 (Self Scoring Worksheet Pool 1) and/or J.5.2 (Self

Scoring Worksheet Pool 2), the Offeror shall be eliminated from

further consideration for award."

The Self-Scoring Sheets will be validated by the Government by the

supporting documents submitted and needs to be included in the

proposal. All scoring elements must be substantiated by the

Offeror with supporting contractual documents.

Attachments

Page 123 of the RFP: L.5.2.3.5 Relevant Experience project Period of Performance.

“For each Relevant Experience Project submitted, the Offeror will receive additional

points if the period of performance meets or exceeds the following:…”On the self-

scoring worksheet it states, “These values are only for the portion of the project that is

contained on the PPIRS or Past Performance Substitute Form. If the project is only

partially completed, then the duration and total value should reflect that.” Despite the

instructions, the self-score worksheet implies that you can only claim credit for the

months already exercised. This seems to give an advantage to work that has expired

or is near expiration, versus work that is ongoing. It would also give an advantage to

contractors who extended their period of performance via protest. Would the

government consider awarding the points to projects (IF they are on-going) for the

entire period of performance and disqualify any portion of the project that was

extended by bridge or protest?

The current methodology treats value and duration equitably.

Offerors are permitted to take credit for all work that they have

performed, regardless of when the work was performed so long as

some portion of the period of performance, including the base and

any option periods, falls within the last five years from when the

RFP closes.

The Self Scoring Sheet (Attachments J5.1 and J.5.2) will be

corrected in the RFP to not require those elements be validated by

the PPIRS or J.6 Past Performance Substitute Form. Only the

Contractual Documents may be used to validate the scoring

elements in the Relevant Experience Project that were previously

marked as solely for the PPIRS or J.6 Past Performance Substitute

Form.

Attachments

16

Attachment J.10 details how to correct an incorrect NAICS code for relevant projects.

In some instances, a NAICS code was never assigned to a federal project. Should we

still use the same form and just put “N/A” or equivalent in the box in Section II, letter

c, and request that the Contracting Officer identify the correct NAICS code?

Yes. The RFP lists several sources of substantiating the NAICS

Code of the Relevant Experience Project. If none of these have an

identified NAICS Code, then J.10 NAICS Code Confirmation Form

may be used and the Contracting Officer will list the awarded

NAICS Code as "none".

Attachments

J.6 Past Performance Substitute Form:

J.6 Past Performance Substitute Form, Item a. (Contract Number/Project Number)

asks for the “Contract number or Project number that you are evaluating.” Some of

our clients use internal agency project numbers to identify projects. These may or

may not correspond with the PIID number that is coded into FPDS for the project.

Is it acceptable for the client to use the internal project number they have assigned

the project, or do we need to direct them to use the corresponding FPDS PIID

number?

The text field provided for “k. Contract Effort Description” is only 94 characters in

length. We do not feel that we can adequately describe our contract effort in this

limited amount of space. Could the Government provide additional space for the

description? (Preferably 300 characters or more.)

When using FPDS-NG to substantiate a NAICS Code, the Offeror

shall submit enough information to substantiate that the contractual

document's contract/task order/project number relate to what is

included in the FPDS-NG report.

Attachments

We have a scenario in which we have a uniquely qualified Relevant Experience

Project where the Prime Contractor is unreachable and no longer available to

complete the Substitute Form. However, we do maintain contact with the Govt.

Contracting Officer and the Contracting Officer’s Technical Representative.

All past performance information for Relevant Experience Projects

shall be completed by someone authorized to rate the performance

of the Offeror. Since the Government does not have privity to the

contract between the Prime Contractor and the Subcontractor, the

Government cannot rate the past performance of the

Subcontractor.

Attachments

How will the assessment or handling of the potential appearance of a conflict of

interest where competing offerors may be evaluating each other?

HCaTS team recognizes Prime Contractors are not required to rate

their Subcontractors and complete the J.6 Past Performance

Substitute Form, and First-Tier Subcontractors need to prepare for

that event. First-Tier Subcontractors will make a business decision

whether or not to submit their past performance rating(s) with their

proposals. With that said, GSA believes Prime Contractors will be

incentivized to fairly rate their First-Tier Subcontractors to maintain

their relationship for future work. Since the Government does not

have privity to the First-Tier Subcontractors, it would not be

appropriate for the Government to rate the First-Tier Subcontractor.

Attachments

What happens if the performance rating for the First-Tier subcontractor is different

than the performance rating assigned by the government to the federal prime

contractor?

GSA is only evaluating the past performance information of the

Offeror and will not consider the past performance information of

another entity; therefore, it will not matter if the Prime Contractor's

past performance rating differs from the past performance rating of

the First-Tier Subcontractor.

Attachments

17

, Section L.2.4 indicates that there will be 40 awards in each pool. Are these

40 small business awards, or a combination of 40 large and small business awards?

Both contract vehicles, Unrestricted and Small Bussiness, will have

40 contract awards per Pool. This is a total of 160 awards. The

Small Business Contract Vehicle is set-aside for small

business;therefore, all 80 awards will go to small businesses. Any

business size is allowed to apply on the Unrestricted Contract

Vehicle; therefore, the 80 awards could be made up of both small

and large businesses.

Awards

REFERENCE:Unrestricted DRFP, Page 92, Section L.2.4 Single or Multiple Awards.

1) Pool 1; 2) Pool 2. OFFEROR COMMENT/QUESTION: For each pool listing, it

states: “Maximum Number of Multiple Awards: 40”

Is this 40 for the Unrestricted contract only?








Awards

REFERENCE: Unrestricted DRFP, Page 62, Section H.19

OFFEROR COMMENT/QUESTION: Solicitation states that “the Contractor shall

attain a minimum of three task order awards or a total task order estimated value of

$1.5M prior to the exercise of Option I. Failure….may result in a Contractor being Off-

Ramped.” Would the Government consider an alternative metric based on the

number of proposals submitted over time, for example six submissions prior to Option

I? Shouldn’t the goal of using this contract be to encourage companies to submit

quality proposals over time without potentially reducing the pool of qualified

companies?

The RFP will be amended to include language allowing Contractors

to substantiate a good faith effort in responding to solicitations

solicited under their respective Pool(s).

Awards

G.2.6 This is a clarification with regards to section G.2.6 and if there will be 1

awarded contract, or 2 (one for each pool). Based on that clarification it is our

assumption that if 2 contracts are awarded, there is no need to have 2 key personnel

per contract; only 1 PM and 1 CM for the overall IDIQ; however, (see

recommendation on line 6) large business only needs one contract total.

If an Offeror submits one proposal for both Pools, the Offeror will

be awarded two separate contracts provided that they win awards

in both Pools.

Awards

In section I.2.3.4, it states that, “The Government may require continued performance

of any services within the limits and at the rates specified in the contract. These rates

may be adjusted only as a result of revisions to prevailing labor rates provided by the

Secretary of Labor.” Earlier in the DRFP you mentioned adjustments to labor rates

based on the employment cost index (ECI). Do you consider prevailing labor rates

and the ECI to refer to the same criterion for adjusting labor rates under HCaTS?

Yes Awards

H.23.2 7. Is the “lowest scoring contractor” the contractor that scored lowest of all

HCaTS awardees in the original HCaTS competition?

Yes Awards

18

FAR 15.304(c)(1) requires that price or cost “shall be evaluated” in a best value

procurement. The RFP merely requires the Agency to determine a price is “fair and

reasonable,” which is an independent determination that an agency must make. See

FAR 15.402(a). The RFP provides that awards will be made to the highest

technically-rated proposals with fair and reasonable pricing. Doesn’t this evaluation

scheme violate the requirement that price/cost serve as an evaluation factor?

Price can be evaluated and considered fair and reasonable in many

different ways. By providing all Offerors with a pre-determined

direct labor rate range of acceptability for each labor category,

Offerors need to submit for evaluation their direct and indirect costs

as per their accounting system. If a cost element exceeds any of

the thresholds prescribed in the RFP, an Offeror is also permitted to

submit a justification for our consideration. Therefore, all proposals

considered for award will have their fully burdened rates evaluated

and considered fair and reasonable to be eligible for award.

Awards

Section F.5.1, Deliverable and Reporting Requirements. We do not object to any of

the compliance measures themselves; however, there is some redundancy and

duplication of effort imposed on industry by requiring HCaTS SB Contractors to both

certify and update compliance data in existing government databases (such as the

Department of Labor VETS-100 compliance database/web portal, as only one

example out of more than a dozen), and then email duplicate copies of these same

certifications and records to [email protected] (or, alternatively, manually upload the

items to the HCaTS SB Management Module (HMM)). Rather than requiring this

duplication of effort, which creates an additional regulatory burden on small

businesses, we recommend that software interfaces be developed to allow the HMM

to access these other Government systems to automatically collect the existing

compliance data. Please note that the SBA recently found that “small businesses

bear a larger burden from regulations than large businesses.” Therefore, any efforts

the HCaTS team could make towards streamlining the regulatory compliance

processes associated with HCaTS SB would be greatly appreciated by industry and

would help control industry’s regulatory compliance costs. (Contractors must pay their

staff members for the time it takes to manually input these duplicative documents and

certifications into the HMM and to email these duplicative documents to the HCaTS

program management office, so automating these tasks by building bridges between

the HMM and other Government databases is recommended.)

As our IT infrastructure evolves, the contracts will be modified

changing the need to update in multiple systems.

Awards

Section G.5, Option Determination. We recommend the last sentence in the first

paragraph be changed slightly to read “If necessary, the HCaTS PMO has also

included one six-month option to extend the initial ordering period of HCaTS SB

contracts.” Adding the word “initial” in this way clarifies that the six-month extension

applies to the initial ordering year, and does not constitute an Option 1 period.


amended.

Awards

19

Section H.19, Minimum Task Order Awards or Estimated Value. Much like with the

GSA Multiple Awards Schedules, participation on HCaTS SB requires intensive self-

marketing, with no guarantee of success; therefore, it seems like the minimum task

order award amounts / estimated value of awards required to avoid being Off-

Ramped from HCaTS is a bit onerous for small businesses, particularly

disadvantaged ones. The GSA Multiple Awards Schedule program requires a

minimum of $25,000 in contracts during the initial contract year to remain active on

Schedule; this seems like a better financial metric or milestone for gauging the

performance of small business on HCaTS SB to prevent dormancy status or Off-

Ramping.




Awards

G.3.1 We believe an excessive CAF outside that of current similarly structured

IDIQs (e.g., GSA Alliant and OASIS) will limit the use of HCaTS. Is there a proposed

range or not-to-exceed cap to the CAF, and if yes, will the Government provide it?

The RFP will be amended to include the CAF once it is agreed and

decided upon.

CAF

Section B.1.8, paragraph one, states, “GSA and OPM operating costs associated with

the management and administration of HCaTS are recovered through a CAF.” Does

this cost get passed along to the federal client seeking services, or to the contractor

providing them?

The Contract Access Fee (CAF) is passed along to the Federal

customer.

CAF

B.1.8 and G.3.1 For large task orders, will the government consider a CAF cap?

Justification/Reason/Explanation: A CAF cap has been introduced on several other

large Federal IDIQs and has proven to encourage greater participation by all

agencies, increase the IDIQ's competitiveness with the CAFs of other

agencies/vehicles, and overall, enhance the marketability of the IDIQ contract.

The Contractor Access Fee has not yet been established, but

several methods are being considered.

CAF

Section B.1.8, Contract Access Fee. To reduce the regulatory burden on OPM/GSA

and industry alike, rather than calculating and monitoring varying Contract Access

Fee amounts, can the Government simply set one fixed percentage rate for the CAF,

much as the Industrial Funding Fee (IFF) for the GSA Multiple Award Schedules

(MAS) program is fixed at 0.0075 of contract value?

The CAF has not yet been determined. CAF

What fees will apply under HCaTS? The Contract Access Fee has not yet been determined. CAF

Section L.5.4.14 indicates the Contractor’s Key Personnel for Contracts Manager

provide verification that they have a Certified Professional Contracts Manager

(CPCM). Would the government consider equivalency language to indicate either

years of experience or a Certificate in Procurement and Contracts Management from

the University of Virginia (or similar University) which is recognized by the National

Contract Management Association (NCMA)?




Certifications

Page 143, Section M.7. There are no indicated points for the Contract Manager

certifications.



wide

Certifications

Page 142, Item L.5.4.9, we suggest that in addition to providing points for advanced

degrees for Human Capital/Resources and ISD, that points also be awarded for

advanced degrees in Organizational Development or Industrial/Organizational

Psychology.




Certifications

20

CMMI Level 3 is more relevant to IT or Software Development programs and not

Human Capital programs. Would the government consider removing this as a scoring

element? The CMMI certification will be removed from the RFP.

Certifications

In this section of the draft RFP, under Compliance Table Item H.6.14, the table

requires that the Certified Professional Contracts Manager (CPCM) maintain their

Human Capital and Human Resources Certification. We believe that it should state

that they maintain their CPCM. Please confirm.




Certifications

Will the government consider a PhD in a scientific discipline addressing human

learning, e.g., Cognitive Psychology, as a substitute for a degree in Instructional

Systems Design?




Certifications

Will the government consider a minimum of 3-years of full-time university-level

teaching experience as a substitute for CPLP certification?




Certifications

Section H states, “The Council created a directory of accredited Six Sigma providers

that is available at the Council's website at www.sixsigmacouncil.org/. L.5.4.10 states,

“Verification requirements include a copy of the Offeror’s Six Sigma Black Belt

Certification from an International Association for Six Sigma Certification accredited

provider.” Please confirm that certifications from organizations accredited by the

International Association for Six Sigma Certification, but not listed on the Council’s

website, meet the HCaTS requirements.




Certifications

Will the government consider a PhD in a scientific discipline addressing human

and/or organizational behavior, e.g., Cognitive Psychology, as a substitute for an

advanced degree in Human Capital or Human Resources?




Certifications

This section of the draft RFP states that one scoring element is ISO 14001:2004.

Would the government remove ISO 14001:2004 from the scoring table, since

certification for an Environmental Management System does not apply to the HCaTs

scope of work or KSAs?

Yes, the Final RFP will have this scoring element removed. Certifications

Please confirm that the scoring of the certifications in sections L.5.4.9 through

L.5.4.14 is relevant to the two key personnel, the Corporate HCaTS Program

Manager (CHPM) and Corporate HCaTS Contract Manager (CHCM). Given L.5.4.14

applies to the Corporate HCaTS Contract Manager (CHCM), confirm that these points

will be granted for this sole individual. Similarly, L.5.4.9 through L.5.4.13 apply to the

Corporate HCaTS Program Manager (CHPM) and thus points will be granted for this

single individual.




Certifications

Would the Government consider adding points for a Certified Federal Contracts

Management (CFCM) certification in addition to the CPCM?




Certifications

If additional points are given for key personnel having a degree in human capital

management or human resources, doesn’t it make equal sense also for the contracts

manager key personnel to be awarded points for having a degree in accounting,

finance, or an MBA?




Certifications

Will the (40) in each pool make-up companies or individual within the companies?

Contracts will be awarded to the companies that submitted the

selected proposals under their respective DUNS Number.

Contract Vehicles

21

Please provide clarification on the contractual mechanism. Specifically, please

explain how is this vehicle going to be implemented as there is mentioned in the draft

solicitation of various types of contracts types.

All contracts will be awarded as Fixed Price with Economic Price

Adjustment (EPA). Ordering Contracting Officers are permitted to

award any type of contract at the task order level in accordance

with the FAR and their agency supplement to the FAR.

Contract Vehicles

Since most of the applicable training NAICs codes are applicable to small business

entities, please indicate how training activities are going to be assigned to large

businesses and on what basis?

Based on the results of market research, Ordering Contracting

Officers will choose the appropriate contract vehicle and Pool(s)

that meet the requirements of their specific acquisition.

Contract Vehicles

(Section M.6.3), p. 140 How can a large firm compete for Pool 1 or Pool 2 with the

respective size standards?

Under the Set-Aside Contract Vehicle, no other than small business

concern can submit a proposal for consideration. Under the

Unrestricted Contract Vehicle, an Offeror can be either a small

business or other than small business, depending on their business

size under each Pool.

Contract Vehicles

Is it correct to assume that offferors should propose 2 key personnel (a program

manager and a contracts manager), regardless of whether an offeror is proposing in

Pool 1, Pool 2, or both pools?

Offerors may choose to submit two separate Contractor Key

Personnel per Pool or use the same Contractor Key Personnel for

both.

Contractor Key

Personnel

Sections H.6.9 – H.6.14 encourage key personnel to have various certifications

throughout the life of the contract. Does the Government intend for ALL key

personnel to achieve and maintain ALL of these certifications or is it the intention that

each of the two key personnel maintain the pertinent certifications. Would the

government consider specifying the required or desired certifications for the

Corporate HCaTS Contract Manager separately from those for the Corporate HCaTS

Program Manager?




Contractor Key

Personnel

Will the government consider equivalent degrees and certifications? For instance,

would the government consider a degree in Applied Behavioral Sciences equivalent

to a Human Capital/ Human Resources degree and a Leadership Coaching

Certificate from recognized institutions such as Georgetown University as an

acceptable coaching certificate?




Contractor Key

Personnel

REFERENCE: Unrestricted DRFP, Page 143, Section M.7, Table entry L.5.4.14

OFFEROR COMMENT/QUESTION: There are no point values listed for contract

professionals in the Unrestricted Solicitation,

but they are listed in the Small Business Solicitation. What are the point values

associated with this table entry in the Unrestricted Solicitation?




Contractor Key

Personnel

Will the 2 key personnel ( Corporate HCaTS Program Manager (CHPM) and

Corporate HCaTS Contract Manager (CHCM) ) be the only ones to gain points for

having certifications referenced on pages 128-129.




Contractor Key

Personnel

Can you confirm that there are only 2 key personnel- Corporate HCaTS Program

Manager (CHPM) and Corporate HCaTS Contract Manager (CHCM).

Correct, there are only two Contractor Key Personnel. Contractor Key

Personnel

L.5.4.9 Key Staff Degree in Instructional Systems Design (ISD). Would a Masters

degree in Education/Curriculum & Instruction count as an Instructional Systems

Design (ISD) degree. ISD is a relatively recent term and is not used by education

graduate schools.




Contractor Key

Personnel

22

H.6.9-13 The Program Manager at the IDIQ level is primarily responsible for the

proper use, dissemination, and overall management of the vehicle, from the Offeror’s

perspective. The Program Manager is rarely directly responsible for execution of

individual task orders. The preferred qualifications listed in Sections H6.9 – H 6.13

are much more appropriate for Task Order leads than for the IDIQ PM. Since Task

Order leads are not key personnel for the IDIQ, recommend eliminating the additional

scoring points for qualifications held by the IDIQ PM. If the HCaTS team feels

additional qualifications for the IDIQ PM are essential, we suggest that H6.11 Project

Management Professional (PMP) is the most relevant to the job of the IDIQ PM.




Contractor Key

Personnel

L.5.4.9/10/11/12/13/14 stipulate that, “The Offeror shall only receive credit for a

maximum of one certification or degree per Contractor Key Personnel.”

DAI requests clarification as to whether the limitation on certifications is one

certification within each category identified, or one certification (total) for each key

person. (An individual identified as a key person for HCaTS may indeed have more

than one of the listed certifications.




Contractor Key

Personnel

G.2.6 The technical skills and professional qualifications/certifications associated with

the Pool 1 and Pool 2 NAICS codes are significantly different. Given this and the

CHPM senior, high-level program management duties outlined in Section G.2.6.1, it

seems appropriate and prudent for contractors to assign a Corporate HCaTS SB

Program Manager (CHPM) for each of the identified MA-IDIQ Pools for which it is

competing.

DAI strongly recommends the definition of Contractor Key Personnel contained in

Section G.2.6 be revised to include a Corporate HCaTS SB Program Manager

(CHPM) for each of the identified MA-IDIQ Pools for which a contractor is competing.




If an Offeror is applying under both Pools, the same Contractor Key

Personnel can be used and the Offeror need naught submit two

separate Contract Managers and two separate Program Managers.

Contractor Key

Personnel

G.2.6.1-G.2.6.2, H.6.9-H.6.14, L.5.4.9-L.5.4.14 We recommend the Government

consider removing the human capital and training-related certification requirements

for the key personnel more appropriate to task order performance. We support

leaving intact related program management and contract certifications directly

relevant to the successful operation of the HCaTS PMO.




Contractor Key

Personnel

G.2.6 Will the Government please confirm that the prohibition against billing for

Contractor Key Personnel applies only to the CHPM and CHCM, and not to any

additional key personnel that may be designated at the task order level?

The prohibition against billing for the CHPM and CHCM only

applies at the contract level. Contractors are permitted to propose

any labor category and rate at the task order level for the Ordering

Contracting Officer's consideration.

Contractor Key

Personnel

Section L.5.4.9, paragraphs two and three, states, “Verification requirements include

a copy of the Offeror’s (CPLP) Certification from the Association for Talent

Development (ATD) or Bachelor’s Degree or higher in Instructional Systems Design

(ISD) from an accredited university or college…The Offeror shall only receive credit

for a maximum of one certification or degree per Contractor Key Personnel.” Does

this apply to only to the two Contractor key personnel listed in the Draft RFP or can

anyone on the proposed team possess these certifications?




Contractor Key

Personnel

23

H.6.14, paragraph 1: The intent of the preference for key personnel with contract

management certifications is not clear. We request that the HCATS PMO clarify if this

competency is required for individuals delivering services to the government

customer or for staff who support the company’s contract management functions




Contractor Key

Personnel

H.6.13, para 5: We recommend that that the preference for key personnel with

degrees in human capital and human resources be expanded to include other

degrees in relevant fields of study. The preference for key personnel with Bachelor’s

degrees in human capital or human resources does not encompass the full scope of

degrees relevant to HCaTS KSAs. For example, degrees in industrial psychology and

organizational development would be directly applicable to the scope of work

referenced in the DRFP. Additionally, degrees related to the training component of

HCaTS (e.g., Bachelor’s or post graduate degrees in Education) are not adequately

accounted for.




Contractor Key

Personnel

L.5.4.9 - L.5.4.14 and M.7 - H.6.9 - H.Corporate HCaTS Program Manager (CHPM)

and Corporate HCaTS Contract Manager (CHCM): The duties and requirements as

outlined in G.2.6.1 and G.2.6.2 are reasonable and consistent with those for similar

positions on Governmentwide contracts. Sections L.5.4.9, L.5.4.10, L.5.4.11,

L.5.4.12, L.5.4.13, and L.5.4.14, however, add language indicating that "it is

encouraged" that these CHPMs/CHCMs have a Certified Professional in Learning

and Performance (CPL) Certification, a Six Sigma Black Belt Certification, a Project

Management Professional (PMP) Certification, Coaching Certifications, Human

Capital and Human Resources Certifications and Degrees, or Certified Professional

Contracts Manager (CPCM), Industry Certification in Contract Management - Defense

(ICCM-D) or Industry Certification in Contract Management - Federal (ICCM-F)

Certification, respectively. The scoring under M.7 dds additional points for these

accreditations. This additional language in Section L and scoring in Section M

overemphasizes the value of specific degrees and certifications as they relate to the

ability to manage a vehicle such as HCaTS. Most of these would more appropriately

be applied at the task order level. This may have unintended consequences-- taking

the focus away from capability and experience. It would be anticipated that in order to

gain additional points, Offerors would seek out individuals to propose for these

positions solely based on the fact that they have specific degrees or certifications--not

the most qualified to manage this IDIQ contract. These additional degrees/

certifications are not indicators of potential success as a CHPM or CHCM. It is

believed that GSA is seeking individuals that will be truly engaged in managing this

vehicle. The use of evaluation points should bring genuine value to HCaTS, not be

utilized simply as a method to include an additional means to score. It is requested

that GSA delete the language in L.5.4.9 through L.5.4.14 and further H.6.9 through

H.6.14 - encouraging specific degrees and certifications. It is further requested that

the additional points noted for these items in M.7 be eliminated. Once eliminated, the

RFP language would reflect the language ultimately included in the OASIS contracts

(where there were similar objections).




Contractor Key

Personnel

24

G.2.6 This clause clearly states that there are no minimum qualification requirements

established for Contractor Key Personnel. Accordingly, it is requested that the 4th

paragraph under G.2.6 be amended to read: "The Contractor shall ensure that the

HCaTS CO has current point-of-contact information for both the CHPM and CHCM. In

the event of a change to Contractor Key Personnel, the Contractor shall notify the

HCaTS CO and provide all Point-of-Contact information for the new Key Personnel

within 5 calendar days of the change." This amended language is in conjunction with

a request to delete the requirements under H.6.9, H.6.10, H.6.11, H.6.12, H.6.13, and

H.6.14.




Contractor Key

Personnel

We believe the certification requirements for the Corporate Program Manager and the

Corporate Contracts Manager are excessive based on their respective roles:

· As our experience with OASIS has shown, the Corporate Program Manager

role is intensively focused on managing and promoting the vehicle itself. This role is

not necessarily involved in the service delivery associated with a particular task order.

The current certifications required for this position far exceed the actual requirements

to successfully manage and promote this vehicle.

· For the Corporate Contracts Manager role, the person most qualified to fill this

role is our OASIS Contracts Manager because she is already familiar with the unique

structure of the two vehicles and their similar reporting requirements. However, she

doesn’t have a background in human capital/training and under the current scoring

system, we would forego points if we proposed her.

We recommend reducing the proportion on points allocated to key personnel. For

example, the Corporate HCaTS Program Manager and Corporate HCaTS Contract

Manager could be credited for one or two certifications rather than up to six, as is

currently presented in the draft scoresheet. This way, we believe the HCaTS team will

get personnel better suited to the underlying CHPM and CHCM roles. It can be left to

the customers to decide what skills they need for service-delivery on a task order-by-

task order basis.




Contractor Key

Personnel

Add labor categories that reflect the level of expertise and credentials needed to carry

out high-level Human Capital programs envisioned under HCaTS, specifically adding

labor categories that require postgraduate degrees in relevantfields, specifically

including Ph.D.’s in industrial/organizational psychology and M.A./M.Ed.’s in

instructional design.




Contractor Key

Personnel

Evaluatethis category based on the past performance of the key personnel and their

educational experience.




Contractor Key

Personnel

25

G.2.6 We strongly recommend that the Government use relevant human capital and

training experience criteria (currently not included) in lieu of extensive certifications as

the key determinant to evaluate whether Contractor Key Personnel have the requisite

professional experience and education in the KSAs to qualify for a position at the

IDIQ level. This would significantly reduce the Government's risk of offerors

submitting key personnel who may be highly certified to score additional points, but

lack true human capital and training expertise and proven abilities to manage the

master contract. We recommend that the extensive certification requirements be

applied at the Task Order level.




Contractor Key

Personnel

M.7 , L.5.4.14 There are no point values listed for contract professionals in the

Unrestricted Solicitation, but they are listed in the Small Business Solicitation. What

are the point values associated with this table entry in the Unrestricted Solicitation?




Contractor Key

Personnel

G.2.6.1, G.2.6.2 We believe that the additional points given for key personnel with

the certifications for CPLP, ISD, Six Sigma Black Belt, PMP, Coaching, Human

Capital and HR, CPCM and ICCM-D & ICCM-F incentivize contractors to propose key

personnel that maximize evaluation points versus proposing key personnel with

significant experience with large multiple award IDIQs. The additional qualifications

may be more appropriate for a specific task. Therefore, would the Government

consider the credit for CPLP, ISD, Six Sigma Black Belt, PMP, Coaching, Human

Capital and HR, CPCM and ICCM-D & ICCM-F for key personnel be removed at the

contract level and allow agencies the flexibility to add these requirements at the task

order level?




Contractor Key

Personnel

Section L.5.4.13 (page 132) asks for human capital certifications. Please confirm

that we can claim this certification by submitting the appropriate evidence for a key

person having a Ph.D. in industrial/organizational psychology.




Contractor Key

Personnel

We strongly believe that the key staff requirements should focus on experience rather

than on credentials. Based on the scoring sheet in section M, it appears that it is the

government’s goal is to have a Contractor identify a single employee as CPHM who

has as many of the certifications as possible, rather than any experience directing

projects or managing large contract vehicles. We would argue strongly that the

certifications in section H.6 and elsewhere in the DRFP (e.g., CPLP, ISD, Six Sigma,

coaching) are not universally relevant to HR, human capital, and training and

development work. We recommend that they be removed from the overall contract

level. Agencies should have

the flexibility to add such requirements when they are relevant to specific HCaTS task

orders.




Contractor Key

Personnel

We believe that credit should also be given for a degree in industrial/organizational

psychology and other related degrees in addition to an HR or HC degree. As the draft

RFP notes in C.1.1 Key Service Areas, “OPM’s experience is that customers have

requirements that require solutions drawing from many different disciplines of study

and areas of expertise.” At a minimum, we suggest you add the words “or in a highly

related field of study” to the rating template and give equal points to degrees in fields

that are relevant to work that will be performed via HCaTS.




Contractor Key

Personnel

26

In section F.5.1 (Deliverable and Reporting Requirements) within the table in rows

H.6.9 through H.6.14, do these refer only to changes in key personnel? That is, do

they mean that within 15 days of substitution, or a change, in key personnel, a

contractor needs to notify GSA of the certifications of the new key personnel?




Contractor Key

Personnel

Do you mean for the table in section B.2.1 to apply to key personnel (as defined in

sect. G.2.6), such that if key personnel have 20 years of relevant work experience

that is an equivalent substitution for a doctorate? Will key personnel be given the

same points for the years of experience as for the certification or degree?




Contractor Key

Personnel

G.2.6.1 Specialized certifications and degrees for CHPMs on large MA-IDIQs are

highly unusual, and in this case, don’t closely align with the CHPM duties in G.2.6.1.

Specialized degrees and certifications for key staff are appropriate at, and should be

tailored for, individual task orders. However, providing extra evaluation points for

specialized certifications and degrees for the IDIQ incentivizes offerors to propose a

CHPM that maximizes evaluation points rather than a CHPM with experience

managing large MA-IDIQs. Will the government consider removing all extra

evaluation points for specialized certifications and degrees for the CHPM? If the

government provides extra evaluation points for the

specialized certifications listed above, it risks placing importance on and measuring

factors that are not relevant to a CHPMs ability to successfully manage the HCaTS

program. The government will miss out on pool of highly valued professionals that

have the equivalent, or better, of such certifications in years of business experience

and direct experience managing large IDIQs, and their ability to add, or continue to

add, substantial value to GSA, OPM, and our mutual customers. We recommend the

government encourage certain certifications and degrees only at the task order level

if relevant for a specific customer requirement.




Contractor Key

Personnel

G.2.6.2 and H.6.9-13 These specialized certifications and degrees for CHCMs on

large MA-IDIQs are highly unusual, and in this case, don’t closely align with the

CHCM duties in G.2.6.2. Providing extra evaluation points for these specialized

certifications and degrees for the CHCM incentivizes offerors to propose a CHCM

that maximizes evaluation points rather than a CHCM with experience managing

large MA-IDIQs. Will the government consider removing all extra evaluation points for

these specialized certifications and degrees for the CHCM?

Justification/Reason/Explanation: If the government provides extra evaluation points

for the specialized certifications listed above, it risks placing importance on and

measuring factors that are not relevant to a CHCMs ability to successfully manage

the HCaTS program. The government will miss out on pool of highly valued contract

management professionals that have the experience managing large IDIQ.




Contractor Key

Personnel

L.4.1 Are the requirements in Volume 4, L.5.4.14 (CPCM, ICCM-D Level III, or ICCM-

F Level II Certificate) required or desired? Unlike the other requirements in Volume 4,

the wording of, “If applicable” is missing at end of the title.




Contractor Key

Personnel

27

What is the total number of Key Personnel that an Offeror can put forward to meet

the certifications listed on pages 146-147?




Contractor Key

Personnel

Recommendation 1: Eliminate Points Allocated for Key Personnel We found the

rationale for allocating points to Key Personnel to be somewhat confusing and

contradictory. Our understanding is that allocating points for Key Personnel implies

that the government believes that Key Personnel with certifications will be more

qualified to manage a large Indefinite Delivery Indefinite Quantity (IDIQ) and that it

will also create another objective discriminator to ensure that the most highly qualified

companies receive awards. Section L indicates that additional points will be given if

the Program Manager and the Contract Office hold certain certifications. Key

personnel are given points for:

• Certified Professional in Learning and Performance (CPLP)

• Degree in Instructional systems Design (ISD)

• Black Belt Certification

• Project Management Professional (PMP) Certification

• Coaching Certification

• Human Capital or Human Resources Certification

• Degree in Human Capital or Human Resources

• Certified Professional Contracts Manager

• Industrial Certification in Contract Management-Defense Level III

• Industry Certification in Contract Management Federal Level III

• Certified Professional Contract Manager




Contractor Key

Personnel

28

The awarding of points for certifications seems to run counter to the requirement

stated in Section G.2.6 which is “There is no minimum qualification requirements

established for Contractor Key Personnel. Additionally, Contractor Key Personnel do

not have to be full-time positions; however, the Contractor Key Personnel are

expected to be fully proficient in the performance of their duties.” We see several

pitfalls with this approach. First the role of the key personnel as defined in the draft

RFP is to serve as the “primary points-of-contact to resolve issues, perform

administrative duties, and other functions that may arise relating to HCaTS contracts

and task orders solicited and awarded under HCaTS contracts.” A secondary role not

explicitly stated is to support GSA and OPM in driving client work to this contract.

The fact that an individual has the certifications listed above does not demonstrate or

imply that the individual has any experience in resolving IDIQ issues or performing

IDIQ administrative duties – or has any meaningful experience whatsoever in

managing large IDIQs. The certifications specify either functional/technical

competence (e.g., in Instructional System Design, or Human Capital), or academic

training in Contracts Management – but not successful large IDIQ contract

management experience in either case. We believe that individuals with relevant

functional/technical certifications (e.g., Six Sigma Black Belt, Coaching, etc.) are

more valuable to clients if deployed to perform task orders, develop solutions that

address client challenges and ensure deliverables are of high-quality. Analogously,

individuals with certifications in contract management might be able to effectively

perform as IDIQ managers – but relevant certifications alone, absent demonstrated

successful experience, does not offer the Government the certainty that we believe is

required in the critical roles defined for Key Personnel.




Contractor Key

Personnel

Second, it would be possible to assign an individual with several of these

certifications as Key Personnel for the sole purpose of scoring points. The proposed

individual would serve as just a “figure head”, but not be truly responsible for

performing most of the duties required for managing this IDIQ after award.

Third, assume an individual proposed as Key Personnel holds multiple certifications

and the company is awarded a contract over another bidder where the Key Personnel

points were the deciding factor. Then suppose that specific individual leaves the

successful bidder and that company is unable to replace their Key Personnel with

another holding similar multiple certifications as required in Section G.2.6. “The

Contractor shall maintain throughout the ordering period of HCaTS, at a minimum,

the accreditations at time of contract award for all Contractor Key Personnel.” Will

that company then lose their award and another company be given an award to

replace it?

We recommend that points not be allocated for Key Personnel certifications because

the certifications are not an objective evaluation factor for determining if Key

Personnel are qualified to manage a large IDIQ. Our second recommendation offers

a more viable and effective means to measure a company’s ability to manage large

IDIQ contracts and drive work to them.




Contractor Key

Personnel

29

G.2.6 Please clarify that, in the following passage, the word “accreditations” refers

ONLY to accreditations that provided contractor extra points in proposal evaluation.

“NOTE: The Contractor shall maintain throughout the ordering period of HCaTS, at a

minimum, the accreditations at time of contract award for all Contractor Key

Personnel.”




Contractor Key

Personnel

L.5.4.9 "...degree in Instructional Systems Design (ISD)" and "Advanced Degree in

Instructional Systems Design (ISD)". Will the government accept equivalent

bachelors or advanced degree in the field of Education, similarly to the qualification in

l.5.4.1.3 that states "a Degree in Human Capital or Human resources," since the ISD-

specific program title has only been incorporated into accredited schools in the recent

past?




Contractor Key

Personnel

L.5.4.14, what are the point value, total max points per element, and total max

possible points for the Certified Professional Contracts manager (CPCM), Industry

Certification in Contract Management- Defense (ICCM-D), or Industry Certification in

Contract Management - Federal (ICCM-F) Level III?




Contractor Key

Personnel

The RFP key personnel requirements state there are points allocated for a CPLP

degree or for an advanced ISD degree, but on the self-score worksheet, there are

only points for the CPLP. Will the advanced ISD degree still be allotted points?




Contractor Key

Personnel

The RFP key personnel requirements also state points are allocated for a contracts

management certification, but on the worksheet, there are no fields or points to

represent this credential. Will this qualification be removed?




Contractor Key

Personnel

Did the Government intend to include points for the three items under L.5.4.14? If so,

could those points be included prior to the release of the final RFP in order to help

inform bid/nobid decisions?




Contractor Key

Personnel

L.5.4.14. does the CPCM certification identified refer to the National Contract

Management Association (NCMA) CPCM certification?




Contractor Key

Personnel

H.6.9, M.7 Training services are broad ranging from analysis, design, development,

evaluation, etc. Also, new tools and technologies are being used in learning all the

time. By definition, these services are performed by individuals with broad range

academic and professional credentials.

The requirement of an ISD degree is too limiting. We suggest that GSA expand the

qualifications in H.6.9and M.7 to include a broad range of degrees such as Adult

Education, Leadership Development, Instructional Technology, etc.

Also, we suggest adding experience in lieu of specific degrees and certifications.




Contractor Key

Personnel

30

H.6.10, M.7 There are very few training and human capital development contracts

that require a Six Sigma black belt certification. Assigning point values to this

certification will give an advantage to niche companies and large systems integrators

rather than to companies that provide a broad range of true human capital and

training capabilities. We suggest that GSA remove the points associated with the Six

Sigma black belt certification and request that such a certification, if deemed

necessary in the future, be requested at the task order level.




Contractor Key

Personnel

H.6.10, M.7 There are very few training and human capital development contracts

that require coaching certifications. Assigning point values to this certification will give

an advantage to niche companies rather than to companies that provide a broad

range of true human capital and training capabilities. We suggest that GSA remove

the points associated with coaching certifications and request that such certifications,

if deemed necessary in the future, be requested at the task order level.




Contractor Key

Personnel

H.6.13, M.7 Degrees in Human Capital are relatively new and offered by few

academic institutions. Experienced human capital professionals often have degrees

or advanced degrees in I/O Psychology, Psychology, Human Development and other

related fields.

Human Capital services are broad ranging from strategy, workforce planning, and

data analytics to transactional human resources services. By definition, these

services are performed by individuals with broad range academic and professional

credentials. We suggest that GSA expand the qualifications in H.6.13 and M.7 to

include a broad range of degrees such as I/O Psychology, Psychology and other

related fields, Human Development

Suggest adding experience in lieu of specific degrees and certifications




Contractor Key

Personnel

H.6.14, M.7 The NCMA certification process is lengthy and NCMA certification is

not the only indicator of contracting expertise. We suggest that GSA add an “in lieu

of” clause to H.6.14 and M.7 allowing for a law degree or 10 years of experience to

be a substitute for the NCMA certification.




Contractor Key

Personnel

Attachment J.9, Contractor_Key_Personnel_Form_HCaTS_SB_draft. We

recommend that you consider adding data entry fields to this form to allow

Contractors to input information about any conventional BA/BS/MA/MS/PhD degrees

the key principals have obtained, e.g., Bachelor’s Degree in Education. These

general degree categories are still relevant and indicative of each key staff member’s

expertise. It is expertise worth considering.




Contractor Key

Personnel

31

The draft self-scoring worksheets (Attachments J.5.1 and J.5.2) provide points for

demonstrating staff with bachelor’s or advanced degrees in Instructional System

Design (ISD) and Human Resources (HR) or Human Capital (HC). Degrees relevant

to ISD, HR, and HC may vary greatly. For example, a trained expert in ISD may have

a degree in fields such as Education, Human Resources Development, or English

Composition. Similarly, a trained expert in HR or HC may have a degree in fields such

as Public Administration, Business Administration, or Psychology. Which degrees will

the government accept as evidence of degrees in ISD, HR and HC?




Contractor Key

Personnel

Section M.7 (Page 143) does not identify points allocated to key personnel with

CPCM, ICCM-D or ICCM-F certifications. Can GSA please identify the points

allocated to these certifications?




Contractor Key

Personnel

Section G2.6 (Page 35) states “there is no minimum qualification requirements

established for Contractor Key Personnel.” Given this, as well as the fact that IDIQ

and GWAC Program and Contract Management personnel are not typically human

capital practitioners, will the government reconsider awarding points to Contractors

who provide Key Personnel with human capital certifications including coaching

certifications, instructional design certifications, and the like? These certifications are

largely held by practitioners providing direct services to clients, rather than

administrative personnel handling the management of contracts internally on behalf of

Contractors.




Contractor Key

Personnel

Key Personnel

The Coalition has similar comments concerning the additional credit allotted for

contractor key personnel. The responsibilities outlined in G.2.6.1 and G.2.6.2 for the

corporate HCaTS program manager and contract manager are reasonable and

consistent with those of similar positions for other government-wide contracts.

However the additional points given for certain certifications in Sections L and M are

unique and will likely have negative unintended consequences if included at the

master contract level. The concern is that personnel who have these certifications

may not be the best contacts for managing HCaTS over the life of the contract.

Experience managing government-wide contracts is much more relevant to contract

performance and agency customer satisfaction. The additional points given for

personnel with these certifications incentivize contractors to propose key personnel

that maximize evaluation points versus proposing key personnel with significant

experience with large multiple award IDIQs who are best suited to managing HCaTS.

The additional qualifications for key personnel may be more appropriate for a specific

task. Therefore, we recommend that credit for CPLP, ISD, Six Sigma Black Belt,

PMP, Coaching, Human Capital and HR, CPCM and ICCM-D & ICCM-F for key

personnel be removed at the contract level and allow agencies the flexibility to add

these requirements at the task order level.




Contractor Key

Personnel

32

Section B.2.1 - Labor Categories and Standard Occupational Classifications / The

table on Page 7 of the DRFP lists experience equivalents for various degrees. Can

the government please clarify the experience and degree substitutions? We would

suggest Master’s Degree = Bachelor’s Degree plus 4 years’ experience; and a

Doctorate = Masters+4 years or a Bachelors+8 years.




Contractor Key

Personnel

Section M.7 – Point Values for Relevant Experience Projects, Past Performance

Ratings and Accreditations / How will experience of Contractor Key personnel be

rated? The table in

Section M.7 gives points for certifications, but no points for: years of experience,

relevancy of experience, or government experience.



have company-wide accreditations. A Contractor Key Personnel's

experience need naught be disclosed and will not be evaluated.

Contractor Key

Personnel

L.5.4.9 – Key Personnel: the scoring elements for key personnel include six (6)

different qualifications/certifications. In section G.2.6, it states that the contractor shall

assign a Corporate HCaTS Program Manager (CHPM) and Corporate HCaTS

Contract Manager (CHCM). Must the two (2) proposed key personnel each hold all

six (6) of the certifications to receive maximum points?




Contractor Key

Personnel

Comment: In section L.5.4.9 – Key Personnel, the scoring elements for key personnel

include six (6) different qualifications/certifications. In section G.2.6, it states that the

contractor shall assign a Corporate HCaTS Program Manager (CHPM) and

Corporate HCaTS Contract Manager (CHCM).

Recommendation: Some of the scoring elements for key personnel would not

necessarily align with qualified candidates for CHPM and CHCM positions. We

recommend defining additional key personnel roles such as Program or Project

Manager roles for which certifications like a Certified Professional in Learning and

Performance (CPLP) or Coaching Certification might be better applied.

The HCaTS team has removed the Contractor Key Personnel



Contractor Key

Personnel

Page 132 of the RFP: L.5.4.13 HUMAN CAPITAL AND HUMAN RESOURCES

CERTIFICATIONS AND

DEGREES “Verification requirements include a copy of the Offeror’s 1) Human

Capital Strategist (HCS) Certification from the Human Capital Institute (HCI), 2)

Professional in Human Resources (PHR) Certification, Senior Professional in Human

Resources (SPHR) Certification, Global Professional in Human Resources (GPHR)

Certification, or Human Resource Business Professional (HRBP) Certification from

the HR Certification Institute (HRCI), 3) Human Resources and Training (HRT)

Certification from American Management Association (AMA), 4) Human Resources

Management Certification from the Graduate School USA, or 5) Bachelor’s Degree or

higher in Human Capital or Human Resources from an accredited university or

college.” / The SHRM Senior Certified Professional (SHRM-SCP) certification is

recognized as the new gold standard of HR certifications. Will the government add

that certification to the list of certifications held by key personnel eligible for points?




Contractor Key

Personnel

33

On page 36-37 of the DRFP, it lists the duties of the Corporate HCaTS Program

Manager and Corporate HCaTS Contract Manager. On pages 128-129 and

Attachment J.9, it lists several accreditations and certifications for which GSA/OPM

will award extra points if our proposed personnel hold them. We feel that a qualified

person performing the duties listed on page 36-37 would most likely not hold the

majority of these accreditations and certifications. Would GSA/OPM consider

lowering or eliminating the bonus points for holding these accreditations and

certifications?

HCaTS Team has removed the Contractor Key Personnel scoring

element due to Industry Feedback. The final RFP will only have

company-wide accreditations.

Contractor Key

Personnel

In Section M.7’s Point Value for Relevant Experience Table, there are currently no

points listed associated with L.5.4.14, the Contractor Key Personnel Corporate

Contracts Manager (CHCM). Will GSA/OPM please provide the points for this

certification? If points are to be awarded, would GSA/OPM consider using National

Contract Management certification of CFCM in addition to its certification of CPCM for

purposes of additional point awards?




Contractor Key

Personnel

Section G.2.6, pg. 35, Paragraph 1 calls for two (2) key personnel, the Corporate

HCaTS Program Manager (CHPM) and Corporate HCaTS Contract Manager

(CHCM):

Are the two key personnel referenced in section G.2.6, pg. 35, the only key

personnel?

If we are submitting candidates to satisfy personnel with the required PMP, Six

Sigma, HCI, etc., are those individuals also considered key personnel?

The CHPM and CHCM are the only two Contractor Key Personnel

that are to be proposed by an Offeror.

Furthermore, HCaTS Team has removed the Contractor Key

Personnel scoring element due to Industry Feedback. The final


Contractor Key

Personnel

Per the note on page 35, does the PMP certification and Six Sigma Black Belt

certification have to be held by the CHPM or CHCM in order for the company to

receive points for their certificatio




Contractor Key

Personnel

Section G.2.6 pg. 35 Key Personnel and Sections L.5.4.9-L.5.4.14, pages 128-130;

The RFP currently provides conflicting Key Personnel requirements and if our

interpretation is correct, requires a large number of Key Personnel (approximately 22

including the CHPM and CHCM) to be submitted without duplication across areas

identified in the proposal (PMP, Six Sigma, HCI, ISD, CPLC, etc.) in order to receive

points for those certifications. Additional clarification is required since the Key

Personnel information on page 35 (including the note about holding more than one

certification) conflicts with the information in sections L.5.4.9 - L.5.4.14 on pages 128 -

130 which indicates that the Offeror shall only receive credit for a maximum of one

certification or degree per Contractor Key Personnel.

Will the government please clarify the Key Personnel requirements?

Offerors shall only propose two Contractor Key Personnel per

proposal. If submitting under both Pools, the Offeror may propose

the same Contractor Key Personnel (for a total of 2) or different

Contractor Key Personnel (for a total of 4).




Contractor Key

Personnel

Why is the government only giving credit for one certification per Contractor Key

Personnel?




Contractor Key

Personnel

How does it diminish the value of any single certification if multiple certifications are

held by one person?




Contractor Key

Personnel

34

Given that this is an IDIQ contract vehicle and not an actual task order, how does the

government justify the need for a company to have 20 different individuals identified

as key personnel in order for a company to score the maximum points for sections

L.5.4.9, L.5.4.10, L.5.4.11, L.5.4.11, L.5.4.12, L.5.4.13, and L.5.4.14?

Offerors shall only propose two Contractor Key Personnel per

proposal. If submitting under both Pools, the Offeror may propose

the same Contractor Key Personnel (for a total of 2) or different

Contractor Key Personnel (for a total of 4). If submitting under both

Pools, the Offeror may propose the same Contractor Key Personnel

(for a total of 2) or different Contractor Key Personnel (for a total of

4).




Contractor Key

Personnel

Would the government consider requiring offerors to demonstrate current

certifications on an annual basis vs. requiring that each certification be held by one

specific key personnel?




Contractor Key

Personnel

Section H.6.9, pg. 54, paragraph 1: “Contractor Key Personnel are encouraged to

have a (CPLP) Certification or a Degree in Instructional Systems Design (ISD) during

the entire ordering period of their HCaTS contract.”

Are ISD degrees and CPLP Certifications interchangeable in terms of maintaining

the offeror’s certifications for the life of the contract? In other words, if a person with a

CPLP certification leaves and a person with an ISD degree is hired, will this meet the

requirements of the contract?

Do the key personnel with these certifications need to be the key personnel defined

on page 35 – the CHPM and CHCM?




Contractor Key

Personnel

Section H.6.13, pg. 55, paragraph 1: “Contractor Key Personnel are encouraged to

have one of the following Human Capital or Human Resources Certifications or a

Degree in Human Capital or Human Resources that focus on human resources

strategies and consulting services for HR organizations…”

Q20. Is this requirement and the points associated with it only applicable to the key

personnel defined on page 35 – the CHPM and CHCM?




Contractor Key

Personnel

Section H.6.13, pg. 55, item #5. “A Bachelor’s Degree or higher in Human Capital or

Human Resources from an accredited university or college.”

There is a broad range of degree programs relevant to this field including M.S.

Industrial and Organizational Psychology, B.S. Organizational Management, B.S.

Organizational Counseling, M.S. Organizational Development, B.S. Applied

Behavioral Science, B.S. Labor and Employment Relations, B.S. Educational

Psychology, B.S. Education, B.S. Education, and an MBA with a focus area.

Please provide additional clarification on the government’s definition of a Human

Capital or Human Resources Bachelor’s Degree?




Contractor Key

Personnel

For example, do Human Capital degrees include a Masters in I/O Psych?

Organizational Development? Social Psychology? MBA?




Contractor Key

Personnel

Are alternative degrees acceptable? HCaTS Team has removed the Contractor Key Personnel scoring



Contractor Key

Personnel

35

Will you accept equivalents, or establish criteria for equivalents (such as years of

experience)?




Contractor Key

Personnel

For example, would OPM consider awarding extra points for a Masters or PhD in I/O

Psych?




Contractor Key

Personnel

Contractor Key Personnel Form, Section I, a. (Company Name) only allows

companies to enter 39 characters of text, and Section IV, c. (Company) only allows

companies to enter 36 characters of text. These text fields are too small for us to

provide our full company name.

Can the government expand these blocks to at least 45 characters?

J.9 Contractor Key Personnel Form, Section II, c. (Position) only allows companies to

enter 20 characters of text. This text field is not large enough to provide the complete

title for several positions. For instance, the title “Corporate HCaTS Program Manager”

is 31 characters, so most of this title would not fit.

Can the government expand this block to accommodate longer position titles?

HCaTS team has removed the Contractor Key Personnel scoring

element and Contractor Key Personnel Form due to Industry

Feedback. The final RFP will only have company-wide

accreditations.

Contractor Key

Personnel

Can Contractor Key Personnel be the same for each pool (for a total of 2) or are

different contacts required per pool (for a total of 4 key personnel)?

If submitting under both Pools, the Offeror may propose the same

Contractor Key Personnel (for a total of 2).

Contractor Key

Personnel

HCaTS type work is intellectually driven. Is B.3.1 where GSA anticipates labor

categories that reflect the level of expertise needed to perform high-level human

capital programs,e.g. PhDs in industrial/organizational psychology and M.A./M.Eds in

instructional design?




Contractor Key

Personnel

Reference Contractor Key Personnel Form, Section III. PROPOSAL SUMMARY-

KEY PERSONNEL ACCREDITATIONS, Question “e” - How many valid "Human

Capital and Human Resources" Certifications and Degrees do the key personnel hold

combined?




Contractor Key

Personnel

The answer options, “3 and 4 or more” don't appear to support the scoring identified

the self-scoring sheet. The scoring sheet implies that an offeror should only take

credit for either a “certification or degree” worth 50 points. If you have an advanced

degree then it would be 75 points. Our understanding of the RFP instructions is that

an offeror shall only take credit for one degree or certification per category. Ref page

129 RFP, “The Offeror shall only receive credit for a maximum of one certification or

degree per Contractor Key Personnel.” If this is still true, then the answer to question

3. Should not have an option for “4 or more”




Contractor Key

Personnel

If the key personnel can qualify for both a certification/bachelors and an advanced

degree, then L.5.4.13 should add up to 250 and the language in the RFP should be

clearer.




Contractor Key

Personnel

We recommend that given the scope of the HCaTS solicitation, the HR degrees

should be evaluated separately from the certifications and not be evaluated together.

Ref page 142 and 143 Draft RFP and the scoring sheet also. In addition, a

Bachelors degree should receive more merit than a certification and not equal to a

certification as currently demonstrated.




Contractor Key

Personnel

36

Beyond EVMS, GSA and OPM should re-evaluate the need for each of the other

systems, certifications, and clearances listed in the Draft RFP and include in the

evaluation criteria only those that are absolutely necessary for a majority of the work

expected to be performed under the contract. For those systems, certifications, and

clearances that may not be needed for a majority of task orders, OPM and GSA

should state in the RFP that it is strongly encouraged that contract awardees

demonstrate proactive steps to move towards specific certifications and systems and

that failure to do so may impact future task orders and off-ramp decisions.

All Contractor Key Personnel accreditations will be removed from

the RFP, along with the CMMI and ISO 14001 certifications.

Contractor Key

Personnel

3. Page 35 of 144 . . . G.2.6 Contractor Key Personnel reads . . . “The

Contractor shall maintain throughout the ordering period of HCaTS, at a minimum,

the accreditations at time of contract award for all Contractor Key Personnel. For

example, if a Contractor’s proposal included a Project Management Professional

(PMP) Certification and Six Sigma Black Belt Certification and made a part of contract

award, then the Contractor Key Personnel shall maintain a Project Management

Professional (PMP) Certification and Six Sigma Black Belt Certification for the

duration of the HCaTS ordering period.”

Comments/Suggestions: Not all qualified personnel are going to have the same

accreditations. For example, is someone who has a PMP and is a certified coach

less qualified than someone who has a PMP and a Six Sigma Black Belt? No, they

just have different certifications. Requiring contractors to replace key personnel with

someone with the exact same certifications would be onerous to say the least. We

recommend the statement be reworded accordingly . . . “The Contractor shall

maintain throughout the ordering period of HCaTS, at a minimum, the same quality of

key personnel as they are replacing. Quality would be evidenced by certifications,

experience, and education.”




Contractor Key

Personnel

10. H.6.9, M.7 Key Personnel Qualifications

The KSAs listed are very broad, but the qualifications of the key personnel are very

limited.

Training services range from analysis, design, delivery to technology and are

performed by a wide range individuals with different academic and professional

credentials based on the type of work. For example, an ICF certified coach is required

specifically for performing coaching services, and PMP is required for project

management.

The requirement of an ISD degree is too limiting.

Comments/Suggestions: Expand the qualifications to include years of experience

and deleting the requirements for certifications since different certifications are

required to perform different services.




Contractor Key

Personnel

37

11. H.6.13, M.7 The KSAs listed are very broad, but the qualifications of the key

personnel are very limited. Degrees in Human Capital are offered by few academic

institutions. Some academic institutions are awarding Certificates in Human Capital

Management.

Experienced human capital professionals often have advanced degrees in I/O

Psychology, Psychology, Human Development, HR and other related fields.

Human Capital services are broad ranging from strategy to transactional human

resources services. These services are typically performed by individuals with broad

range of academic and professional credentials. For specialized services, people with

the right credentials are selected, such as classifications work.

Comments/Suggestions: Recommend expanding the qualifications to include years

of experience and deleting the requirements for certifications since different

certifications are required to perform different services.




Contractor Key

Personnel

H.6.10, M.7 & H.6.12, M.7 There are very few training and human capital

development contracts that require coaching and Six Sigma black belt certifications.

Assigning point values to this certification will give an advantage to niche companies

and large systems integrators rather than to companies that provide a broad range of

human capital and training capabilities.

Comments/Suggestions: Remove the points associated with the Six Sigma black belt

certification and request that such a certification, if deemed necessary in the future,

be requested at the task order level.




Contractor Key

Personnel

H.6.14, M.7 The NCMA certification process is lengthy and NCMA certification is not

the only indicator of contracting expertise. Even government COs don’t have this

certification.

Comments/Suggestions: GSA should add an “in lieu of” clause to H.6.14 and M.7

allowing for a law degree or 10 years of contract management experience to be a

substitute for the NCMA certification.




Contractor Key

Personnel

Page 141, Section M.7. It is unclear whether the government intends to award points

for projects being

inclusive of Cost-Reimbursement for two total projects or two projects per pool.

An Offeror is able to receive points for two Cost-Reimbursement

projects per Pool.

Cost Reimbursable

Will the Government consider awarding points under this section for cost

reimbursable Travel/ODC’s under Time and Material and Fixed Price contracts?


amended to reflect it.

Cost Reimbursable

While a project awarded primarily as a firm fixed price contract, with a cost

reimbursement line item be awarded points for cost reimbursement contracting? For

example, a fixed price contract for custom training solutions with travel or materials

reimbursed at cost.

Any amount of cost-reimbursable type contract will be considered

as a cost-reimbursable type Relevant Experience Project and will

receive points for this scoring element. However, Offerors cannot

take credit for this scoring element if the cost-reimburseable

element is for travel or other costs associated with travel.

Cost Reimbursable

L.5.2.3.7: Relevant Experience with Cost Reimbursement Contracts. Can GSA please

clarify whether the task order must be 100% cost reimbursement or if an offeror can

qualify if a contract has one or more CLINs that are reimbursable (for example

reimbursable CLINs for travel and/or ODC’s)?

Any amount of cost-reimbursable type contract will be considered

as a cost-reimbursable type Relevant Experience Project and will

receive points for this scoring element. However, Offerors cannot

take credit for this scoring element if the cost-reimburseable

element is for travel or other costs associated with travel.

Cost Reimbursable

38

The DRFP awards extra points for cost reimbursement projects, according to Section

L.5.2.3.7, but not for time and materials or labor-hour contracts. According to B.1.6

Contract Type, HCaTS will allow for all contract types (fixed-price, cost-

reimbursement, time-and-materials, and labor-hour), so we would argue that extra

points should not be awarded solely for past performance that reflects cost

reimbursement contracts.


amended.

Cost Reimbursable

What percentage of the HCaTS task orders (TOs) does OPM/GSA estimate will be

issued as cost type contracts? Section B.2.3 indicates that cost reimbursement TOs

shall only be used for the acquisition of non-commercial items. We assume the bulk

of TOs anticipated will be for commercial services. If so, why are the other types not

allocated points in the M.7 scoring schema? Shouldn’t the evaluation of experience

with these contract types be reflective of the

historical trend of tasks that are expected to be let under HCaTS? Likewise, shouldn’t

the historical trend of contract size be taken into account when limiting the Pool Past

Performance and Relevant Experience Projects to six large contracts performed as a

prime?

We do not have an estimate of how many task orders will be issued

as non-commercial. However, because we are providing Ordering

Contracting Officers with the opportunity to award non-commercial

task orders, we believe that Offerors with prior experience in

administering cost reimbursable is a value add.

Cost Reimbursable

39

References from M.7: L.5.3.2.5; L.5.4.1; L.5.4.2; L.5.4.3

L/M omission: Examining the historical spend by the Federal Government under the

GSA HR and Equal Employment Opportunity Services, 738X schedule contract for

SINS 595-21, HR General Support Services, of the 160 schedule holders in FY 2014,

only 89 vendors had any reportable 738x schedule sales (total approaching $120M).

Only 20 of the 89 had FY 2014 sales exceeding $1M, only 5 vendors had sales

exceeding $4M, and the top three vendors (in sales) accounted for 49% of all HR

General Support Services. The data indicates most sales were below the HCaTS

thresholds for project value (L.5.2.3.4), period of performance (L.5.2.3.5),

subcontracting/teaming (L.5.2.3.6), were firm fixed price (FFP) (i.e., not

ostreimbursement, L.5.2.3.7), and were commercial.As one of the largest providers of

services under GSA 738X Schedule that has provided HR/HCM services for more

than 80 Federal agencies, we have encountered only a handful of cost type contracts.

Our understanding is that the vast majority of tasks issued under TMA and the Army’s

HR Solutions were either FFP or time and materials (T&M) contracts. This history

would lead one to believe that the majority of tasks from both defense and civilian

agencies would be FFP or T&M, and that the vast majority would be small- to mid-

size projects; however, the scoring process only allows for full points for large cost

type contracts.

Suggestion. While the data indicates the majority of the HCaTS-type services

currently acquired by the Federal Government are being delivered by qualified firms

with the capacity for successfully managing a high volume of smaller value contracts;

this important ability is not an evaluation factor in the current draft RFP. To address

this, we suggest minimizing the points associated with cost type contracts for past

performances and adding points commensurate with the historical number or dollar

value for FFP and T&M tasks issued in order to better reflect the anticipated ratio of

TO contract types. Also, we suggest eliminating or lowering the points allocated for

DCMA verified purchasing and estimating systems and instead allow them to be a

disqualifier at the TO level for any cost type TOs issued. We suggest that a better

way to evaluate a contractor’s ability to manage cost type TOs is by using the

standard found in B.2.3., which simply requires the demonstrated capability to comply

with all process and reporting requirements for cost contracting.

We will revisit the allocation of points for each scoring element. Cost Reimbursable

section L.5.1.8 – In regard to the Contractor Team Arrangement (CTA), if there are

multiple partners with multiple entities, do the combined relevant experiences (across

multiple entities together) count towards the total amount of relevant experience

projects acceptable and points awarded as laid out in Section L.5.2.3.6?

When submitting a proposal as a Joint Venture, all Relevant

Experience Projects and associated past performance information

shall have been awarded under the existing Joint Venture's DUNS

Number and not the individual members making up the Joint

Venture.

CTA

Will all Joint Venture and CTA team members all need to be within the size standard

and respective HCaTS Pool that they are applying for access to?

The methodology to calculate your business size can be found in

FAR Section 19.101.

CTA

40

Will the Government consider providing less than full credit for Joint Ventures and

CTAs that claim joint credit for ISO certification and CMMI rating, than Offerors with a

single prime that provide those certifications and ratings?

In order for a Joint Venture to take credit for any accreditation, the

accreditation shall be in the Joint Venture's name.

The DRFP states "The Joint Venture or Partnership, and not the

individual team members, shall represent all proposal submission

documents required under Section L.5.1.8, including all Relevant

Experience Projects, Past Performance, and accreditations, as

applicable, under this solicitation."

CTA

Will GSA be posting the attachments (Part III: Section J) from page 79 of 144 of the

solicitation as part of the DRAFT solicitation? If not, does GSA intend to post these

attachments ahead of the release of the final RFP?

All attachments, except for J.2, were uploaded in the Presolicitation

Notice. All attachments will be included in the Final RFP.

Draft RFP

The Coalition for Government Procurement appreciates GSA and OPM for the

opportunity to comment on the HCaTS Draft RFP and for the ongoing dialogue with

all stakeholders on this important procurement. In the spirit of this Mythbuster’s

dialogue, the Coalition respectfully requests that the comment deadline for the

HCaTS Draft RFP be extended to April 30, 2015. We believe that the additional time

will result in more effective and thoughtful comments to GSA and OPM on the

structure of the HCaTS RFP. Given the strategic importance of this contract in

support of personnel development, human capital services and organizational

improvement government-wide, an extended comment period would be in the best

interest of customer agencies as well as the American taxpayer. The additional time

is also necessary given the substantial update provided in the draft RFP. Thank you

for your consideration and we look forward to continuing the Myth-buster’s dialogue

with you on this procurement.

The HCaTS PMO has extended the deadline for significant

comments from March 30, 2015 to April 15, 2015. Feedback is still

welcome after this deadline up until the RFP is posted. Significant

feedback that may lead to drastic changes of the RFP require more

time on the part of the Government.

Draft RFP

In order to properly review the DRAFT RFP and provide more targeted

comments/questions we respectfully request an extension to submit feedback until

April 13.






Draft RFP

On behalf of PDRI, I am writing to request that the deadline for industry comment to

the above referenced HCaTS Draft RFP be extended one month, to April 30, 2015.

Additional time will be necessary after the attachments listed in Section J are

released. These attachments form much of the basis for scoring industry proposals

and so will warrant close scrutiny by potential offerors. Additionally, the draft RFP

includes significant changes with important implications for the government and for

offerors; allowing additional time for industry response will increase the likelihood of

GSA and OPM receiving the most valuable and useful feedback to incorporate into

this critical procurement.






Draft RFP

How close will this attachment be that is now unrestricted, to the final RFP which will

be issued on or about May 19, 2015.

Several elements in multiple sections of the Draft RFP may change

based on the feedback we receive. It will be the Offeror's

responsibility to read the Final RFP in its entirety and abide in sum

to the terms and conditions.

Draft RFP

What is the reason for the Archive date April 30, 2015 if this is only a draft and a pre-

solicitation notice?

The Draft RFP archive date has been changed to May 15, 2015. Draft RFP

41

Section L.5.1.9, paragraph one, states, “To be eligible for award, the Offeror shall

follow the directions and submit the following information under Volume II.” Should

this be Volume I? The instructions contained in the table in Section L.4.1 on page 97

appear to provide contradictory guidance.

It should state Volume I in L.5.1.9. This will be corrected in the final

RFP.

Draft RFP

Section L.5.1.9.1, paragraph four, describe Sections I - III and V - VIII of the GSA

Form 527, but there is no description of Section IV. Can OPM provide details

regarding Section IV?

Section IV is explained in Section L.5.1.9.1, it is in the same section

as the explanation for Section III.

Draft RFP

M.7, assigns the following points based on the value of a Relevant Experience

Project: Project’s value is equal to or greater than $150,000 but less than $250,000

$250,000 but less than $500,000 on an annual basis – 200 points Project’s value is

equal to or greater than $500,000 but less than $750,000 on an annual basis – 300

points Project’s value is equal to or greater than $750,000 on an annual basis – 400

points These point values differ from those listed in Attachment J.5.2 for Relevant

Experience Projects. Could the government please clarify the points Offerors can

expect to receive based on the value of a Relevant experience Project?

The RFP will be amended to correct the discrepancy. We will


Draft RFP

M7, assigns the following point values to the period of performance of projects

included in Relevant Experience Projects: The period of performance is equal to or

greater than 6 months but less than 37 months. – 100 points The period of

performance is equal to or greater than 37 but less than 61 months – 200 points The

period of performance is equal to or greater than 61 months – 300 points Attachment

J.5.2 assigns 100 points to a Relevant Experience Project if the period of

performance is equal to or greater than 13 months but less than 37 months. This

period of performance differs from the period of performance that qualifies for 100

points listed in Section M.7. Could the government please clarify the variations of the

stated points?

The RFP will be amended to correct the discrepancy. We will


Draft RFP

L.5.1.5 “The Offeror shall answer Questions 2 through 2.C, regardless if the Offeror

is not subject to CAS.” The wording of this sentence is confusing. Can this sentence

be read as: “The Offeror shall answer Questions 2 through 2.C, regardless of whether

or not the Offeror is subject to CAS?”

The Final RFP will be amended to clarify this sentence Draft RFP

L.1 - FAR 52.252-1: The Draft RFP currently references FAR 52.237-10, OCT 1997

version. Please confirm that the final RFP will reference FAR 52.237-10 –

Identification of Uncompensated Overtime – March 2015 version.

Yes, the RFP will include all of the current FAR Clauses as of the

day it is posted.

Draft RFP

Is it possible to make publicly available the MOU that spells out the terms under

which OPM and GSA will cooperate, so that contractors can understand how the

relationship between OPM, GSA, and the OCOs will work?

The MOU was provided in the Draft RFP in Section B. Draft RFP

If the MOU is not available, please answer the following questions:

a. With whom will contractors sign a contract?

b. Will ordering agencies’ agreements be with GSA or OPM?

c. Will ordering agencies' funds be transferred to the OPM revolving fund, some

instrumentality at GSA, or some other fund, and under what authority?

Read the MOU that is linked in the Draft RFP. Draft RFP

Section B.3.3 of the Draft Request for Proposal (page 10) discusses OCONUS work.

If a task order involves OCONUS work, would the contractor support U.S.

Government civilians on United States soil in a foreign area, such as a military base

overseas, or would it be on foreign area/land?

Although technically a possibility, historically the preponderance of

work has been performed in Washington, D.C.

Draft RFP

42

Section L.5.2 (Page 114) states, “A Relevant Experience Project is defined as a

single contract; or, a single task order placed under a master Single Award or Multiple

Award, Indefinite Delivery, Indefinite Quantity (SA/MA IDIQ) task order contract (FAR

Subsection 16.501-1); or, a single task order placed under a Federal Supply

Schedule (FAR Subsection 8.405-2); or, a single task order placed under a master

Single Award or Multiple Award Blanket Purchase Agreement (SA/MA BPA) (FAR

Subsection 8.405-3 or FAR Section 13.303).” Can GSA please define “single

contract” in the context of this paragraph? That is, is a single contract intended to

mean a stand-alone contract not connected to any IDIQ, FSS or BPA? If so, then this

seems to conflict with the sentence in paragraph four which states, “If a single

contract has a task order(s) awarded against it, the Offeror shall submit either the

single contract or the task order(s) as the Relevant Experience Project, but not both.”

Yes, the RFP will be amended adding the definition of a contract. Draft RFP

The point totals for Pools 1 and 2 in Section M.7 (Page 143) do not appear to match

the sums of the individual scoring elements. Can GSA please clarify the individual

and total point allocations?

The RFP will be amended to correct any discrepancies. Draft RFP

In the paragraph following the 6 KSA objectives - "These three KSAs will enable

HCaTS SB to provide Federal agencies..." - does the government mean "these six

KSA's" etc."

The RFP will be amended to correct this discrepancy. It should

state three.

Draft RFP

(Section M.6.3), p. 140 What is the “survey” that you’re referring to? The survey refers to the Past Performance Substitute Form. The

RFP will be amended to correct this.

Draft RFP

Volume 2 (L.5.2) , p.100 Please verify the correct file name. It should be volume 2,

correct? “ABC.VOL1.J4.pdf “

The RFP will be amended to reflect this. Draft RFP

On page 117, there is a statement about the verifiable contractual documents to

substantiate the relevant experience project. What qualifies as “verifiable contractual”

documents? Can GSA/OPM provide examples?

The RFP will be amended to add examples Draft RFP

43

The solicitation takes a hard line against the enabling infrastructure for our economy

and workforce – IT solutions.

• HR technology development and implementation is the fastest growing area in

HR, and Kennedy Information (a research group) indicates that HR Consulting is one

of the fastest growing areas in consulting, it stands to reason that TMA should be in

the technology business within the HR/HC, and OE world – assessment,

requirements, design, development, implementation, evaluation, but not pure O&M.

• HR systems are never static. They are constantly changing as the needs of the

workforce evolve, OPM mandates change, Congress enacts new legislations, etc…

Agencies need a partner that understands human capital strategy AND IT; the

lifecycle of a federal employee; workforce planning; IT design, development, and

implementation; organizational effectiveness; and business process optimization.

That is the only way they can effectively streamline, optimize, and improve the many

systems and tools that support the civilian workforce and mission accomplishment.

Possible mitigation strategies:

• Remove the requirement that non-IT support (software development) can

account for no more that 50% of a TO.

• Remove language specifying that all non-IT support should be “incidental”.

The 50% threshold will be removed from the RFP. Draft RFP

Section C.3.2, pg 19, paragraph 3. “The OCO shall ensure that the aggregate dollar

amount of all ancillary support services and supplies, including IT and non-IT

products and services, is less than 50% of the task order’s awarded amount or

estimated cost. OCOs may establish further restrictions to this threshold; however,

are prohibited from exceeding it at any time.”

HR technology development and implementation is the fastest growing area in HR,

and Kennedy Information (a research group) indicates that HR Consulting is one of

the fastest growing areas in consulting, it stands to reason that HCaTS should be in

the technology business within the HR/HC, and OE world – assessment,

requirements, design, development, implementation, evaluation, but not pure O&M.

Will the government consider removing the requirement that non-IT support

(software development) can account for no more that 50% of a TO.

The RFP will be amended removing this threshold. Draft RFP

Will the government consider removing the language specifying that all non-IT

support should be “incidental”?


amended.

Draft RFP

We recommend that the government remove the requirement on Page 114, Section

L.5.2 of the draft RFP to limit the number of sole source Relevant Experience

Projects.

This restriction has been removed from the RFP. Draft RFP

44

Non-Federal organizations apply a variety of procurement practices that don't lend

themselves to the binary categorization of either sole-source procurements or formal

competitive procurements. Non-federal organizations often employ competitive

processes that do not utilize a formal, transparent RFP process and the binary

evaluation may be misinterpreted by non-Federal survey respondent thus

inappropriately disqualifying a relevant experience project. The HCaTS field is

extremely competitive across industry sectors. How does this requirement serve as a

unique discriminator among offerors? What value does this provide to the

government?

This restriction has been removed from the RFP. Draft RFP

How will the government take this into consideration so that the submission of

Relevant Experience Projects procured through non-federal means are not unfairly

penalized due to a categorization requirement that is not consistently applied across

industries?

The HCaTS team is making the assumption this question refers to

the sole source restriction; this restriction has been removed from

the RFP.

Draft RFP

Section M.3, paragraph one, states, “The HCaTS evaluation team will perform a two-

step screening process for all proposals received. First, the HCaTS evaluation team

will verify that a support document exists for all the evaluation elements in

accordance with the Offeror’s proposal checklist submitted in accordance with

Section J.2 (Proposal Checklist) and compare it to the Offeror’s self scoring

worksheet submitted in accordance with Section J.5.1 (Self Scoring Worksheet Pool

1) and/or J.5.2 (Self Scoring Worksheet Pool 2). Any discrepancies will be treated as

clarifications.” Can OPM clarify what “clarifications” means in the last sentence?

In accordance with FAR 15.306(a), "(1) Clarifications are limited

exchanges, between the Government and offerors, that may occur

when award without discussions is contemplated.

(2) If award will be made without conducting discussions, offerors

may be given the opportunity to clarify certain aspects of proposals

(e.g., the relevance of an offeror’s past performance information

and adverse past performance information to which the offeror has

not previously had an opportunity to respond) or to resolve minor or

clerical errors."

Evaluation

Rather than recommending a minimum dollar figure or a specific number of task

orders, we would suggest that the criteria associated with remaining among the pool

of selected HCaTS contractors—to the extent that there is a need for such

criteria—focus more on indicators of quality (i.e., client satisfaction) rather than the

proposed quantity-focused metrics. In order to enforce the proposed criteria, the

HCaTS vehicle must be marketed well, and government clients must see value in

using the vehicle. Frankly, we have had several clients who we have worked with in

the past through the OPM TMA vehicle decide to stop using the vehicle. For that

reason, we are concerned that vendors may have limited control over how many

contracts they are awarded and what the total dollar value of those contracts are.

Such criteria could also be biased in favor of larger organizations, culling smaller

companies from the HCaTS pool who are doing excellent work but don’t see the

volume of work that the larger vendors do.


amended.

Evaluation

In the event that the government has not provided a rating for a certain rating area in

CPARS, how are those areas evaluated?

The RFP states:

NOTE: If an Evaluation Area was not rated, do not assign a score

for that Evaluation Criteria.

Total the scores and divide that by the number of rated Evaluation

Areas, rounding to the hundredth decimal position. If the

thousandth decimal position is equal to or less than 4, round the

hundredth decimal position down. If the thousandth decimal

position is equal to or greater than 5, round the hundredth decimal

position up.

Evaluation

45

L.5.1.9.1 Financial Resources, Section III, Item 3: Offerors are required to submit the

last full fiscal year statement and subsequent interim statements. If an offeror is a

publicly held company, is it acceptable to provide the web address of the SEC filings

containing this information. Page limitations prohibit publicly held companies from

meeting this requirement.

The RFP will be amended allowing Offerors to submit financial

statements without page limitation. Web addresses will not be

accepted.

Financials

L.5.1.9.1 para3: We recommend that the requirement stipulating that Offerors

should submit GSA Form 527 (“Contractor’s Qualification and Financial Information”)

be removed. Offerors that have a private limited liability partnership structure cannot

distribute financial statements to parties other than their partners, principals, and

lenders. Large size and a strong record of success of Offerors should provide

compelling evidence of the possession of the financial resources needed to serve the

government. To offer an example, EY is a substantial entity, with more than 31,000

people working in the US. The partnership’s fiscal year 2014 total revenues exceeded

$9.9 billion, with growth of 9% or more over the last three years. The requirement of

the submission of GSA Form 527 will prevent such organizations that possess strong

relevant capabilities from responding to the HCaTS solicitation.


amended.

Financials

Will the Government include the three years of “good financial standing” that was a

part of the RFI released for comment in December/January?

All determinations of financial responsbility shall be arrived at by

the information provided by the Offerors. If additional information is

required, the Government may request it.

Financials

Section L.5, Proposal Content, top of page 102; Section L.5.1.7, page 108, list of

forms. Question: We have found that some of our task order awards use Optional

Forms 347 (and continuation page Optional Form 348). Would the Government

please add this form to the list of examples presented in the referenced proposal

sections?

Yes, they will be added to the list of examples presented in the

prorposal.

Forms

Because of the numerous of moving parts- if possible when in the final drafts

submitted, can a checklist can be generated to ensure all information is received.

All attachments, except for J.2, were uploaded in the Presolicitation

Notice. All attachments will be included in the Final RFP.

Forms

What is the average project value and length of performance under the previous TMA

contract?

Per OPM, "Under the previous TMA contract, reimbursable service

delivery was organized into discrete projects in the Office of

Personnel Management’s (OPM) financial information system and

based on available information the average project value was

approximately $2 Million and the average length of performance

was approximately 16 months."

General

Page 118, the section that includes the NOTE does not seems to apply to the

surrounding text. Please clarify.

Yes, this note applies to the surrounding text. The Self Scoring

Worksheet (Attachments J.5.1 and J.5.2) instruct the Offeror to

state where in the contractual documents that various elements are

located. The Offeror will use the contract or task order documents

to substantiate cost-reimbursement type contracts, teaming with or

subcontracting out to 4 or more entities, and demonstrating that the

Relevant Experience Project was within scope of the KSA(s).

General

How many days does the government anticipate offerors will have to prepare a

response to the final RFP?

The Government will provide no less than 30 days, and is still

considering the initial response time. In the event that additional

time is needed the RFPs can be amended to allow it.

General

46

Please confirm that small businesses that are awarded an HCaTS SB contract cannot

bid on TOs issued under the unrestricted HCaTS contract.

Ordering Contracting Officers shall identify a predominant NAICS

Code at the task order level from one of the two Pools under either

contract vehicle (HCaTS or HCaTS SB). Only those Contractors

awarded a contract under that specific Pool under the chosen

contract vehicle may submit an offer against a task order

solicitation.

General

This section requires that the offeror provide a copy of its Compensation Plan,

however, it limits the size to 10 pages. Compensation Plans are corporate documents

that are not generally tailored to an RFP. Would the Government consider deleting

the page limitation for the Compensation Plan?

We will remove the page limitations for this and the

Uncompensated Overtime Plan document

General

The solicitation states that the Offeror will be excluded from further consideration for

award if the total error rate on the Self Scoring Worksheet is greater than 10%.

Before this exclusion is enacted, will the Offeror be notified of the errors and be

provided with an opportunity to justify why the Offeror’s original Self Scored score

should prevail?

This restriction has been removed. General

Procuring practices differ across industry sector. Many non-Federal procurement

organizations source using pre-qualified vendor practices to streamline competition.

During this process, vendors are vetted and evaluated against pre-established criteria

in order to receive an award. This pre-qualified procurement practice is distinguished

as a separate procurement practice from sole source procurements. As such, please

confirm that the government will consider awards using pre-qualified vendor selection

as a competitive award when selecting a response in Section II, Question j.

This restriction has been removed. General

Does the government require a Washington DC based office in order to bid this

contract?

No. General

L.4 If significant source material is required in a volume, a volume might grow beyond

the limits of a 25 MB zip files. Recommend permitting a volume to be split across zip

files if necessary to meet the requirements of the RFP.

This requirement has been revised and the only accepted method

of proposal submission will be via DVD+R. The final RFP will reflect

this change.

General

H.19 (H.25) Without knowing the level of commitment to use HCaTS and HCaTS SB

that GSA and OPM may have received from Federal Government agencies, it is

impossible to ascertain the validity of the metric established in the DRFP. Knowing

the challenge currently faced by OPM in generating more than $5 million annually in

collective OPM-TMA task order value begs the question as to the HCaTS SB

projected annual value upon which this metric is based.

Recommends GSA and OPM identify the projected annual HCaTS SB value basis for

this metric, and include provisions for a metric adjustment should the projected

annual HCaTS SB value not be achieved.

The contract ceiling will be included in the RFP. General

H.3.1 addresses Set Asides. The passage of the 2015 National Defense

Authorization Act allows WOSBs and EDWOSBs to receive sole source contracts as

well as those socio-economic groups mentioned above. Therefore, DAI strongly

recommends that the sentence above be amended to read: “In the event any set-

aside or direct award regulations change during the duration of HCaTS SB, the

HCaTS SB CO reserves the right to unilaterally modify HCaTS SB to reflect the

change at no additional cost to the Government.”

This restriction will be removed in the RFP. General

47

Section G.2.6, paragraph six, states, “All costs associated with contractor key

personnel duties shall be handled in accordance with the Contractor's standard

accounting practices; however, no costs for Contractor Key Personnel shall be billed

to the HCaTS Program Management Office (PMO).” Is it permissible to bill the

government for costs associated with attending task order kickoff meetings and for

activities related to reviewing subcontractor performance?

No. If awarded a contract, Contractors shall not bill the HCaTS

PMO for any costs incurred to administer their contract.

General

Section L.3, paragraph five, states, “This solicitation instructs Offerors to provide

supporting documentation for practically all pass/fail and scored evaluation criteria.

While some sub-sections of Section L may indicate an Offeror shall provide a

particular form of documentation for validation purposes, Offerors may provide

whatever official, verifiable documentation is necessary to validate any pass/fail or

scored evaluation criteria being claimed.” Can OPM provide details and/or examples

of what they would deem to be official, verifiable documentation and details and/or

examples of what they would NOT deem to be official, verifiable documentation?

The RFP will be amended to add examples of what can be

submitted as verifiable documenation.

General

Per Section F3, is there an estimate of approximately what proportion of task orders

are likely to involve work in locations OCONUS versus CONUS?

The preponderence of the work will be performed in Washington,

D.C.

General

L.4.1 : If the Master Table of Contents is to contain all of the documents being

submitted, it is impossible to keep it to one page, especially if the font is 12 pt. Will

the Government consider increasing the page limit to 3 pages to accommodate the

entire listing of files?

This will be revised in the RFP to have no page limitation. General

Would the OPM be open to online/virtual delivery? We propose this delivery option

for three reasons:

1. Online or virtual delivery saves costs in terms of both time and money. Since

no travel is necessary, less expense is required to provide learning transfer and

coaching. When training is performed remotely, we do not need to factor in travel

expenses such as flights, hotels, rental cars, per diems, etc.

2. This also saves the participant time away from work since they can attend right

from their desk.

3. The third, and more important reason is that not all people learn at the same

pace. Some participants can attend a training session once and master the material.

Others need to re-experience material several times in order to retain it. Because

online learning is self-paced, students can learn at their own pace, which allows for

various learning styles.

The KSAs are inclusive of this type of delivery mode. General

If the OPM is not open to virtual delivery, would this disqualify Prevail for this

offering? Would it be possible to propose a partnering agreement where one firm

performs face-to-face delivery and Prevail provides virtual training?

The KSAs are inclusive of this type of delivery mode. General

Would the OPM consider alternative pricing? As is more standard in our industry, we

typically price our services on a per-person, per-course approach instead of hourly

rates (with the exception of as-needed coaching services).

The Ordering Contracting Officer will make the determination as to

the appropriate contract type to award at the task order level.

General

In section F.5.2 (page 32) the row H.19 states the minimum value of work you must

do is $1.5M for HCaTS SB. But later in the actual H.19 section (page 65) it gives a

number of just $1.0M. Which is it?

The RFP will be amended to correct the discrepancy. The values

may change based on additional market research.

General

48

If some of the requirements for obtaining points are not relaxed or we are not allowed

to include subcontractors’ capabilities in Relevant Past Experience, there is a chance

that we may not be able to meet the requirements to bid as a prime contractor on the

Unrestricted HCaTS contract vehicle—despite the fact that we have been an OPM

TMA contractor since 1987, and the contract vehicle has been a vital source of work

for us. In spite of our ability to successfully perform work for Federal agencies through

the OPM TMA vehicle for the past 28 years, the rating scheme as it is currently

proposed, combined with the effort and cost required to prepare a proposal, could

discourage us from submitting a response to this RFP. In addition, we have already

invested a considerable amount of time and money competing and being selected for

the last OPM TMA RFP that was cancelled. For these reasons, we may decide that

we cannot afford to compete for this revision of the contract vehicle if it appears we

are not as likely to be successful. We certainly hope that this is not the case, and that

OPM and GSA use our feedback to revise the HCaTS RFP to allow HumRRO and

similarly situated companies to compete on a level playing field with larger vendors.

The HCaTS team will amend the RFP to also allow First-Tier

Subcontractors to submit experience earned under a Prime

Contractor's contract, task order and/or purchase order. All

experience performed as a First-Tier Subcontractor will be

considered a non-Federal government project.

General

H.7 What types of events or activities are contemplated under the phrase

Administration of CAS?

Any event or activity that changes the Contractor's administration of

CAS.

General

Reference: “No, Offerors will be differentiated by their past performance”

Question: If the main differentiator is Past Performance, would the Government

consider making the Volume 4 Accreditations a requirement at the individual task

order level as opposed to the current MA-IDIQ level?

All past performance is directly related to each Relevant

Experience Project, which can be an IDIQ and/or task order.

General

F.5 Does the requirement only include those systems which meet the CAS? Is the

same true for the SB-set aside? It would appear that it doesn’t per K.2.5 (page 87)

All requirements that are applicable to your contract shall be

maintained throughout the life of the contract. CAS does not apply

to small business as per 48 CR 9903.201-1.

General

Is it the Government’s intent that proposals will not include a traditional technical

approach or management approach as part of the proposal requirements?

Yes General

49

We are very skeptical that HCaTS represents an advantage to individual agencies or

the government as a whole when compared to Federal Supply Schedule 738X. We

see no explanation or justification of any real need for the “down-select” HCaTS

represents. We do not believe the following statements from the DRFP to be

accurate: “In turn, HRS’ Training and Management Assistance Program (TMAP)

ensures the development and delivery of customized human resources, human

capital and training products and services to Federal agencies by managing private

sector contractors in the design, development, and implementation of solutions in the

areas of training and human capital in order to improve agency performance against

performance metrics at the employee, unit, and enterprise levels... “Many human

resources, human capital and training products and services are offered in the

commercial market. However, TMA offers customized solutions that involve

modifications to commercial products and services that are sufficiently significant as

to alter the characteristics or purpose of the products or services. The products and

services delivered under the TMA program focus on federal government

requirements and are exclusively provided to federal government customer agencies.

In all cases, the project deliverables are customized or designed to meet unique

agency specific requirements that cannot be adequately met through the use of off-

the-shelf solutions.” To the contrary, we believe that the position expressed is directly

contrary to the direction provided by OMB in its Cloud First, Shared First, FedRAMP

and HRLoB initiatives. All HCM products and services needed by agencies are

readily available through the commercial marketplace as represented by GSA Federal

Supply Schedules (including 738X) – the sort of product customization referred to by

the DRFP is no longer required in any Federal Government administrative process

and the Federal Government clearly can no longer afford such unnecessarily

customized products. In today’s world of software and IT systems the solutions are

highly flexible and only configuration – not customization – is required. The DRFP’s

customization premise is once again a sign of OPM’s legacy viewpoint that is at least

10 years behind what is commercially available.

Thank you for your comment. General

50

We believe that if there is to be a fundamental purpose of HCaTS – if it is to have a

purpose at all – needs to be articulated with respect to limited highly specialized

professional services that do not involve products in any way. In particular, it must be

recognized that SaaS is a new form of product delivery, not a new form of

professional services delivery and that it is imperative that HCaTS should not be

inconsistent or detrimental to certified HRLoB providers. We are troubled by broad

statements in the DRFP (and accompanied by equally broad graphic displays) such

as, “The scope of KSA 2 is inclusive of, but not limited to, a broad range of human

capital and human resources services. These services shall include, as a part of

talent management and human capital management, the following:

• HR strategy

• Organizational and position management

• Staff acquisition

• Performance management

• Compensation management (excluding payroll)

• HR Development

• Employee relations

• Labor relations

• Separation management.

“The scope of KSA 2 excludes payroll processing, benefits management, and

personnel action processing, which are provided through Public and Private Shared

Service Centers (SSCs).” [Why is this statement limited to only three of the HRLoB

services rather than all elements of HRLoB??]. Similarly, we believe the following

statements are contradictory and ambiguous: “C.3.3 Information Technology (IT), by

legal definition, means any equipment, or interconnected system(s) or subsystem(s)

of equipment that is used for the automatic acquisition, storage, analysis, evaluation,

manipulation, management, movement, control, display, switching, interchange,

transmission, or reception of data or information by a Federal agency. For purposes

of this definition, equipment is used by a Federal agency if the equipment is used by

the Federal agency directly or is used by a Contractor under a task order with the

Federal agency that require its use; or to a significant extent, its use in the

performance of a service or the furnishing of a product. IT is considered an ancillary

support service or product on task orders and may be performed and/or provided only

No comment General

51

Both GSA and OPM must recognize the limitations of their expertise with respect to

solutions. Contrary to either explicit or implied positions expressed in the DRFP,

OPM’s expertise is only in Federal HR policy – OPM has absolutely no expertise –

and a proven track record to the contrary – in HR IT or HR business processes. As a

result, HCaTS should not include solutions such as administrative operations

processes. Avue has repeatedly brought to the attention of GSA, OMB, and OPM

itself that OPM has a clear conflict of interest between its policy and products (fee for

service). Fee for service activities include so-called “assistive acquisition” or “strategic

sourcing” pursuits, which not surprisingly consistently result in the assisted acquisition

or “strategic source” being OPM products and services. This conflict of interest is not

academic and given the fact that OPM’s fee for service operation is $2 Billion Dollars

per year in fees to OPM that is hardly surprising. To give just one example, OPM

[policy] auditors are documented to have repeatedly “bad-mouthed” Avue during DEU

audits and recommended to Avue agency customers that they purchase a different

staffing solution (such as OPM’s USAStaffing software). OPM claims of having

effective “Chinese walls” in place are demonstrably false. In the Draft RFP, OPM’s

confused and conflicted role continues, e.g.: B.1.3 – “Under this agreement, GSA’s

acquisition capabilities, tools and strategic

sourcing experience are merged with OPM’s expertise in human capital and training

to form a more powerful Government solution.” B.3.5 – “OPM will continue to offer

high quality products while taking advantage of GSA’s ability to provide government-

wide cost savings and efficiencies through its federal strategic sourcing expertise.

Through this partnership, GSA will be principally responsible for contract

administration, while OPM will be responsible for policy oversight.” C.1 – “Human

Capital and Training Solutions Small Business (HCaTS SB), through delegated

procurement authority and OPM assisted acquisition services [a clearly non-policy

role], will provide Federal agencies with both direct access and assisted acquisition

access to customized training and development services, human capital strategy

services, and organizational performance improvement services.” As a result, we

believe that, contrary to the current language of the DRFP, that the analysis and

recommendation of IT systems (including SaaS/Cloud) should be expressly excluded

from HCaTS.

No comment General

52

The solicitation encourages firms not to partner, which limits the breadth of

innovation that will be offered to the government under this solicitation and limits

competition from mid-size companies.

• There are no incentives to develop a team with the skills to support the HCaTS

KSAs with the exception of a small business subcontracting plan that may eventually

get exercised.


• To encourage subcontracting to highly qualified small businesses and to satisfy

the socioeconomic goals of the federal government, it is highly recommended that

subcontractor past performance along with qualifications such as ISO and CMMI be

accepted to support the “combined team” capabilities and past performance

credentials if the “bonus point” system, as currently stated, remains.

• Additionally, we would encourage the requirement to submit and “Executive

Summary” that provides the team composition and the strengths offered to GSA/OPM

by the collective capabilities of the team and supporting small businesses including

8(a), SDVOSB, WOSB, HUBZone, etc., that will demonstrate the commitment to

those qualified small socio economic businesses that possess core capabilities

required under HCaTS.

This interpretation is incorrect. All other than small business

concerns under the Unrestricted contract vehicle are required to

have an approved subcontracting plan incorporated into a resultant

contract. Furthermore, Contractors are permitted to form any

teaming arrangement at the task order level as permitted by the

task order solicitation.

General

What existing contracts do GSA and OPM plan to include in the scope of the HCaTS

contract? What agencies that currently have their own contracts within the scope of

this contract have committed to using HCaTS in the future versus their own?

No additional contracts will be included in the scope of HCaTS.

Currently, no other federal agency has committed to using HCaTS.

General

Our firm concurs with the HCaTS team’s decision to allow First-Tier Subcontractor

work to be credited to the Offerors as Commercial Relevant Experience Projects. This

approach seems fair and equitable, and will benefit young 8(a) companies that have

not yet received the full array of SBA Business Development training for federal

sales. Young 8(a) companies often have commercial project references and/or

federal subcontractor experience only, so the HCaTS team’s decision here allows

even the newest of 8(a) firms to have a chance to participate in HCaTS.

Thank you for your comment. General

What consideration will be in place regarding FAR Clause 52-208-9 for AbilityOne?

Ordering Contracting Officers have the ability to add this clause at

the task order level if they determine ancillary services and supplies

can be provided in accordance with 52.208-9.

General

Could you please tell me how many slots each company will have on the

Presolicitation Conference for HCaTS on May 14?

One. The new date for the Pre-Solicitation Conference is May 21,

2015.

Industry Day

A notice was posted on fbo stating that a pre-solicitation conference regarding the

subject effort is scheduled for or around May 14, 2015. Is the government seeking

registration for the pre-solicitation conference at this time?

The HCaTS team has posted on our Interact website at

https://interact.gsa.gov/hrfssi and fbo.gov additional details and

registration information. The new date for the Pre-Solicitation

Conference is May 21, 2015.

Industry Day

I was wondering how to go about registering for the Presolicitation Conference for

Solicitation No: GS02Q15CRR0002. Please let me know. Thank you.

The HCaTS team has posted on our Interact website at

https://interact.gsa.gov/hrfssi and fbo.gov additional details and

registration information. The new date for the Pre-Solicitation

Conference is May 21, 2015.

Industry Day

53

According to a recent GovWin update, "A Presolicitiation Conference remains

scheduled to be held on or about May 14, 2015."

Can the government please confirm if this is the case? If so, will the government

please provide registration information for the conference, or when that registration

information will be available?

The Pre-Solicitation Conference is scheduled for May 21st. The

Government will provide registration information on www.fbo.gov

and interact.gsa.gov/hrfssi

Industry Day

Would the Government allow a “consortium” to bid on the small business set-aside

(assuming it is within limits), comprising several very small and new (~1 year old)

businesses, to propose as a single entity (e.g., under a newly established umbrella

company)? If this is possible, would we be able to use qualifications from any of the

consortium members, given that they would be affiliates of the company that

ultimately holds the contract?

No, the only time an Offeror can use a teammate's past

performance is under an existing Joint Venture. When submitting a

proposal as a Joint Venture, all Relevant Experience Projects and

associated past performance information shall have been awarded

under the existing Joint Venture's DUNS Number and not the

individual members making up the Joint Venture.

Joint Venture

Section M.7 Discussion. The DRFP only allows for joint ventures (JVs) or CTAs, if

they are in place in advance of bidding AND if they use only past performance gained

under the JV or CTA. Depending on how established (i.e., FAR Part 19; SBA 13

C.F.R §121.103(h); or the DCAA CAM), JVs may exist for at most three specific or

limited-purpose business ventures during a 2- year period, making it impossible to

provide the four to six past performances requested. CTAs, formed for the purposes

of one contract and dissolved at contract end will not accumulate the necessary four

to six past performance references.

Suggestion. If it is the Government’s intent to allow JVs or CTAs, it seems practicable

to allow for the use of relevant experience projects, past performance ratings and

accreditations to be allowed from either JV or CTA members in each particular

scoring category.


amended.

Joint Venture

We have provided training services to several federal agencies on the Department of

Commerce’s National Technical Information Service (NTIS) e-Training Systems

Partnership (http://www.ntis.gov/services/partnerships/), which allows federal

agencies to engage a contractor’s services with a simple Memorandum of Agreement

or Interagency Agreement. Contractually, the engagement is considered a Joint

Venture Partnership (JVP) between the contractor and NTIS. How will GSA/OPM

view an NTIS JVP project in terms of relevant past performance? Is it considered an

IDIQ or BPA? Is the contractor still considered the Prime Contractor on NTIS work?

Are we allowed to submit more than one NTIS project to satisfy the past performance

requirements? Are NTIS projects subject to the FAR provisions listed at the bottom of

page 114 because of their method of award, which would limit us to using only one

NTIS project per pool (currently there are no FAR provisions listed on NTIS

contractual documents)?

The RFP will be amended clarifying that in order for a Relevant

Experience Project to count as a Federal project, the Federal

agency has to award the contract or task order in full accordance

with the FAR.






However, when submitting a proposal as a Joint Venture or

Contracting Teaming Arrangement (CTA), all Relevant Experience

Projects and associated past performance information shall have

been awarded under the existing Joint Venture's DUNS Number

and not the individual members making up the Joint Venture or

CTA. A member of the CTA or Joint Venture may not use a contract

or task order awarded to the CTA or Joint Venture on their

individual proposal.

Joint Venture

54

Will the government consider counting past performance of a joint venture as prime

contractor past performance, if the prime contractor can show that they performed the

relevant work and have CPARS/PPIRS or a past performance substitute form clearly

showing the work done by the prime contractor?





Venture.

Joint Venture

GSA should permit the capabilities of each member of a joint venture, or the

capabilities of subcontractors, to be considered when evaluating proposals.





Venture.

Joint Venture

Are the standardized rates (Section J.8) fully burdened? No, these rates are the direct labor rates only. Labor Categories

B.3.2 LABOR SUBJECT TO THE SERVICE CONTRACT ACT (SCA) 1. Graphic

Designers

2. Human Resources Assistants

3. Instructional Coordinators

4. Technical Writers

5. Training and Development Specialists

To the extent that any of the above-mentioned labor categories and/or ancillary labor

for services are within the scope of HCaTS and subject to the SCA in accordance

with FAR Subpart 22.10 and other applicable agency specific regulatory supplements,

the OCO shall identify such work in the task order solicitation and make a

determination as to whether SCA wage determinations are to be applied or not.

QUESTION: What does this mean?

All SCA labor categories will be removed from the RFP. Labor Categories

Labor IDs (4.1, 4.2, 4.3, 4.4) for Compensation, Benefits and Job Analysis Specialists

are mapped to SOC code, 27-3041. Wouldn’t the correct SOC code be 13-1141,

Compensation, Benefits, and Job Analysis Specialists?

These labor categories have been mapped to SOC Code 13-1141,

Compensation, Benefits, and Job Analysis Specialists.

Labor Categories

Labor IDs (6.1, 6.2, 6.3, 6.4) for Financial Managers are mapped to SOC code, 15-

2031. Wouldn’t the correct SOC code be 11-3031, Financial Managers?


Financial Managers.

Labor Categories

Labor IDs (9.1, 9.2, 9.3, 9.4) for Human Resources Specialists are mapped to SOC

code, 11-3121. Wouldn’t the correct SOC code be 13-1071, Human Resources

Specialists?


Human Resources Specialists.

Labor Categories

J.1 Today’s learners expect engaging forms of instruction, ranging from instructor-led,

through blended learning, all the way to computer and/or game-based engagements.

While IT services are out-of-scope (but could be included as ancillary services),

current courseware extensively uses gaming and computer-based instruction,

requiring the use of Multimedia Artists and Animators (SOC 27-1014), Software

Developer and Application Developers (SOC 15-1132). We recommend adding

these labor categories to the HCaTS

Due to the range of ancillary services that could be provided at the

task order level, it is not possible to include every possible labor

category at the contract level. However, Contractors will be

permitted to propose additional labor categories at the task order

level to submit a total solution.

Labor Categories

55

J.1 The current HCaTS labor categories do not include instructors/teachers. We

suggest the use of SOC 25-3099 Teachers & Instructors, All Other be included, as

well as 25-1199, Post- Secondary Education Teachers, All Other

Some teachers and instructors may be mapped to the HCaTS labor

category Training & Development Manager. However, other

teachers and instructors are SCA labor categories, and all SCA

labor categories will be removed from the RFP.

The HCaTS Labor Categories do not represent all possible labor

categories that are in scope. Offerors may propose additional labor

categories not awarded in the contract at the task order level to

provide a total solution.

Labor Categories

J.1 The HCaTS Team deleted (per the latest posted amendment to the DRFP) all

SCA labor categories and stated those are now considered “Ancillary” services.

However, previous labor ID # 26.1-26.4 could easily be mapped to SOC 13-1151,

Training & Development Specialists;, which would be a very welcome and needed

labor family to include in HCaTS

All SCA labor categories will be removed from the RFP. This

change is not due to all SCA labor categories being considered

ancillary.



categories, including SCA labor categories, not awarded in the

contract at the task order level to provide a total solution.

Labor Categories

J.1 The HCaTS Team deleted (per the latest posted amendment to the DRFP) all

SCA labor categories and stated those are now considered “Ancillary” services.

However, previous labor ID # 23.1-23.4, Graphics Designer could easily be mapped

to SOC 27-1041, Multimedia Artists and Animators, which would be a very welcome

and needed labor family to include in HCaTS. These designers are critical to

development and delivery of high-quality instructional content.

Graphic Designers are an SCA Labor Category and all SCA labor

categories will be removed from the RFP.



categories, including SCA labor categories, not awarded in the

contract at the task order level to provide a total solution.

Labor Categories

J.7 For labor category IDs 1-6, the high-end of the direct labor rate range for Senior

level categories equates to the low-end of the direct labor rate range for SME level

categories. However, for labor category IDs 7-21, the low-end of the Senior level

categories equates to the low-end of the SME level categories. Is this overlap among

Senior and SME direct labor rate ranges for labor IDs 7-21 intentional?J

The overlap of $0.01 will be changed in the RFP. Labor Categories

Section J.8, concern Direct Labor Rate Ranges. Can OPM/GSA clarify whether the

amounts listed for the Minimum and Maximum Direct Labor Rate Range are fully

burdened/loaded?

These rates are not fully burdened. Labor Categories

J.1 We recommend that the Government revise the Journeyman range to

accomodate additional rates accompanied by more specific experience

requirements. Currently, the DRFP provides four salary levels relating to

education and years of experience for the HCATs Labor cateogories: Junior,

Journeyman, Senior, SME. Specifically, the Journeyman experience range is

too broadly defined as 3-10 years with a BA/BS or MA/MS degree, which

makes it difficult for the offeror to propose an appropiate labor rate.


amended.

Labor Categories

56

J.1 Please clarify if the years of experience within the levels are to reflect

relevent experience as a manager or experience overall. Currently, the table

of Standardized Labor Cateogories includes several management level

positions. GSA is requesting each position be given a rate with respect to

Junior, Journeyman, Senior, and SME levels.

This is experience overall. Labor Categories

Section B.2.5, it reads: “The contractor may provide separate and/or blended loaded

hourly rates for Prime Contractor labor/each Subcontractor…”. Please verify if the

Government will require the Contractor to provide all Subcontractor fully burdened

labor rates or just Major Subcontracts (defined as doing more that 25% of the work).

Labor categories and rates shall be proposed and awarded in

accordance with the terms and conditions of the task order

solicitation.

Labor Categories

Section B.2.5.1 where it addresses “Escalation” – Is it the Government’s intention to

provide the exact escalation percentages for all future year pricing? Will the

Contractor be required to compute the average annual BLS ECI index for the past

three years in order to determine the escalation rate? Instead of the average BLS ECI

index as the base for escalation, can the Contractor provide their own escalation

based upon historical escalation rates?

Yes, the Government will provide the escalation rates and the

Contractor/Offeror will not calculate the escalation rate at any time.

Labor Categories

Will the Government consider adding Project Manager and Program Manager to the

list of labor categories?

Project managers or Program managers may be mapped to the

HCaTS Labor Category: Managers, All Others. The Offeror shall

reference the SOC descriptions for each Labor Category when

making mapping determinations.

Labor Categories

On page 147, will the Government hold all small businesses (including 8a’s) to the

profit of no more than 7%?

In accordance with the RFP, Offerors are required to provide clear

and convincing rationale for exceeding the 7% threshold.

Labor Categories

Does the Government intend to issue a rate table with specified Labor Categories, or

have Offerors provide rates based on the Government’s specifications of the Labor

Categories?

Yes, Attachments J.7 and J.8 state the required labor categories for

HCaTS. Attachment J.7 Cost/Price Worksheet includes the

accepted direct labor rate ranges for each labor category. The

Offeror will provide the direct labor rates and percentages for cost

elements: G&A, Fringe Benefits, Profit, Overhead.

Labor Categories

Section B.2, Task Order Pricing. Will ordering agency contractors have to determine

prices are fair and reasonable on each task order, where required by FAR and their

agency rules? We appreciate there is no statutory presumption that prices are fair

and reasonable, as there is on GSA schedule orders, but profit will have been limited

during evaluation of HCaTS contract proposal, contractors will have been required to

establish ceiling prices for noncompetitive awards, and escalation will have been

limited at contract level. Along the same lines, what is the Agency’s authority to limit

profit to 7% for each HCaTS labor category? See Section M.8, which refers to

Section L.6.2.

Yes, Ordering Contracting Officers shall determine prices fair and

reasonable at the task order level. The fully burdened labor rates

awarded at the contract level are only used when a sole-sourced

Time-and-Materials task order is awarded; therefore, Contractors

are permitted to propose profit rates lower or higher than what was

awarded in their contract. If a sole-sourced Time-and-Materials

task order is awarded, the Contractor shall not exceed 7% at the

task order level.

Labor Categories

57

L.5.5. Will there be ceiling rates for labor under time and materials task order that are

competitively bid? Answers to previous questions are not clear:

“…the contract ceiling rates will serve the purpose of establishing the ceiling rate at

which labor rates can be awarded at the task order level if a Time-and-Materials Sole

Source task order is awarded. If these two scenarios do not exist, the contract labor

rates can be exceeded, as applicable,” But “HCaTS will follow the OASIS model and

have an established price range for each labor category. The Government will

provide the labor rates, but they have not yet been determined.” Will the upper limits

for labor rates be the SOC rates, which have now been provided?

The only time a Contractor is prohibited from exceeding their

contract ceiling rates is if a sole sourced Time-and-Materials task

order is awarded. If this condition is not met, Contractors are

permitted to propose labor rates that exceed their contract labor

rates for the Ordering Contracting Officer's consideration.

Labor Categories

L.5.5 “These ceiling rates are to be based upon the highest qualified employee within

a given labor category or group, working in the highest paid area within CONUS, on a

highly complex requirement, excluding Secret/Top Secret/SCI.” Q&A “This rate will

be the highest that you would charge the Government even if in the past you have

charged this rate when a subcontractor did the work.”

a. Is the “Direct Hourly Rate” an actual rate paid to an actual employee or

subcontractor in an actual location?

b. If a subcontractor, how can we ascertain how much the employee was paid? May

we use what we paid for the subcontractor in lieu of direct hourly rate with loads?

c. If the rate is an actual rate, is any documentation showing that rate was actually

required? If so, what kind of documentation is required?

d. If a contractor has not paid actual employees or subcontractors in a labor

category, may the contractor use that rate as a contract, as opposed to an ancillary,

rate in bidding on task orders?

e. Is the “most highly qualified” person the most highly paid person?

f. If the rate is NOT an actual payment, is it a market projection? If it is a market

projection, is any documentation of the basis of the projection required? If so, what

kind of documentation is required?

The only time a Contractor is prohibited from exceeding their

contract ceiling rates is if a sole sourced Time-and-Materials task

order is awarded. If this condition is not met, Contractors are

permitted to propose labor rates that exceed their contract labor

rates for the Ordering Contracting Officer's consideration.

When proposing the fully burdened rates, Offerors need to make

several business decisions, in addition to complying with their

accounting system. The Offeror will have to submit documentation

justifying a cost element that exceeds a threshold prescribed in the

RFP for our consideration. If the Offeror's proposed rates do not

exceed any thresholds, no additional documentation is required.

Labor Categories

Recommend that HCaTS allow for a profit rate up to 10 percent consistent with the

FAR as an incentive for industry. A lower cap of 7 percent could have the unintended

consequence of incentivizing vendors to promote use of competing contracts in cases

where the 7 percent cap is unrealistic.

Offerors are permitted to propose a profit rate that exceeds the 7%

threshold and submit documentation to substantiate the reason(s)

why for our consideration. Furthermore, the profit ceiling awarded

at the contract level is only applicable to a sole-sourced Time-and-

Materials task order. Otherwise, Contractors are permitted to

propose any profit rate for the Ordering Contracting Officer's

consideration.

Labor Categories

Once the final RFP for HCaTS is released, we request that all amendments specify

the changes to the solicitation as a result. Contractors report that it was extremely

challenging to manage all of the electronic amendments for OASIS. Improved

organization in this process will help to control contractors’ bid and proposal costs in

response to the HCaTS solicitation.

Any amendments after the Final RFP is posted will be identified in

Section L, 52.252-3. Offerors are required to read the Final RFP in

its entirety, with the understanding that there will be many changes

in it from the DRFP.

Labor Categories

58

L.3.2 If a contract has been novated or otherwise transferred to the Offeror, along

with the staff that performed the work, the Offeror should be able to claim credit for all

the work performed, not just that work performed since novation. This would bring

the scoring criteria in line with Section L5.1.7 where a subsidiary defers its credit to

the Parent under the “meaningful relationship” Corporate structure provision.

The RFP will be amended to state that the meaningful relationship

under a Corporate Structure shall have been in place at time of

contract and/or task order performance.

Meaningful

Relationship

Would the Government please amend the RFP document as

follows:

Offeror shall have performed six Relevant Experience Projects, with four of those

Relevant Experience Projects under a NAICS Code that corresponds directly to a

NAICS Code in the Pool being applied for (see NAICS Code Pool Table below).”

least one Key Service Area (KSA).

We believe that the structure prescribed in the RFP treats all

Offerors equitably at the contract and task order level in a clear and

consistent manner, allowing the Government to determine the

business size at the contract level and task order level consistently.

In addition, without this requirement there is a greater probability of

the same Offerors winning awards in both Pools.

NAICS

REFERENCE: Draft Section J.10 NAICS Code Re-Determination Form; Page 1

OFFEROR COMMENT/QUESTION: Discussion: On April 3, 2015, the Government

issued Section J attachments to the Draft RFP which included Section J.10 “NAICS

Code Re-Determination Form.” This Form states: “Contracting Officers: You are

receiving this form because the Offeror cited in Section I claims that the majority of

the work performed on the contract or task order cited in Section II-A falls within one

of the NAICS codes listed in Section II-E, and not the reported NAICS Code. The

Human Capital and Training Solutions (HCaTS) team is asking that you, as duly

warranted Contracting Officer of the contract or task order cited in Section II-A, certify

that the scope of the contract or task order falls within one of the NAICS codes in

Section II-E, and not the reported NAICS Code.” The above statement appears to be

asking the Contracting Officer to make a re-determination of the appropriate NAICS

code for the work performed under the cited contract; an action which is not legally

permissible. For the HCaTS RFP, the only issue at-hand is an inaccurate reporting in

FPDS of the correct and original NAICS Code assigned to the contract/task order

cited as past performance at the time of its solicitation, not a re-determination of the

NAICS Code. These solicitations/contracts are a matter of public record and easily

verified. There should be no need for a warranted Contracting Officer to be involved

or to certify. Question: Would you consider requiring Offerors who have a past-

performance contract citation with a NAICS Code that has been incorrectly reported

in FPDS to submit the page(s) from the original solicitation and/or contract which

reflects the correct NAICS Code vs the one inaccurately reported in FPDS?

Yes. The RFP will be amended allowing Offerors to submit

contractual documents to substantiate NAICS Codes. In addition,

the RFP will have an order of precedence so Offerors know which

documents we will consider over others. For example, if FPDS-NG

has a different NAICS Code then the contractual documents, the

NAICS Code identified in the contractual documents will be used.

On the Self-Scoring Worksheet (J.5.1 and J.5.2), the Offeror will

select the document that is validating the NAICS Code based on

the order of precedence.

NAICS

59

Will the government consider adding NAICS code 611310 to the eligible codes for

qualification in pool 1? Many contracts for customized training & development

services (KSA #1) are awarded under this NAICS code and should be considered

when evaluating eligibility for pool 1.

The HCaTS PMO chose the NAICS Codes that best fit the work

that represent the scope of all three KSAs. As per the definition of

this NAICS Code, we have determined it does not fit the scope of

HCaTS.

NAICS

Will GSA eliminate NAICS Code 624310, Vocational Rehabilitation Services, from the

procurement? According to the U.S. Census Bureau, the NAICS code applies to

organizations that provide job training to the unemployed or to those who are

underemployed due to job market disadvantages. This focus appears inconsistent

with the scope of HCaTS. OPM and GSA have expressed that the intent of the

HCaTS contract is to address the human capital and training requirements of the

existing federal workforce. Neither agency has indicated that an objective of the

contract is to train individuals to be eligible for federal employment or to be eligible for

a better federal position. This is the focus of organizations that provide Vocational

Rehabilitation Services. Preparing an individual for a position is significantly different

than improving the individual’s skills or performance. If the goal of the HCaTS

procurement is the latter and not the former, the assignment of the NAICS Code

624310 will not attract the appropriate industry partners.

NAICS Code 624310 Vocational Rehabilitation Services is used

when providing training, career counseling and placement for

returning veterans. This is within scope of HCaTS and allows for

work done by our customers helping veterans.

NAICS

We have multiple relevant projects reported in PPIRS with NAICS codes not in the

HCaTS pools, but with contract documents (SF 1449) that identify HCaTS pool

NAICS codes. If the NAICS codes reported in the PPIRS and/or FPDS-NG report

differ from the NAICS code listed on the contract award documents or solicitation

documents, how will the primary NAICS code for the work be determined?

The RFP will be amended allowing Offerors to submit contractual

documents to substantiate NAICS Codes. In addition, the RFP will

have an order of precedence so Offerors know which documents

we will consider over others. For example, if FPDS-NG has a

different NAICS Code then the contractual documents, the NAICS

Code identified in the contractual documents will be used. On the

Self-Scoring Worksheet (J.5.1 and J.5.2), the Offeror will select the

document that is validating the NAICS Code based on the order of

precedence.

NAICS

Previous versions of the HCaTS procurement documents indicated that an email from

a duly warrented contracting officer was acceptable evidence of a change in the

primary NAICS code for a relevant experience project, however now attachment J.10

provides a form to be filled out. Will the government still accept emails provided from

the contracting officer in lieu of the form since the emails have already been provided

to the offeror?

No, the Offeror must have a Government Assessing Official use

Attachment J.10 NAICS Code Confirmation Form if they are

requesting that the NAICS Code for the Relevant Experience

Project be considered as a different one than the contract or task

order was originally awarded under.

NAICS

L.5.2 To ensure the broadest qualified competition for the HCaTS

program—supported by objective demonstration of similar work related to HCaTS-

identified NAICS codes—we recommend that the Government consider adding the

following NAICS codes for this solicitation: Pool 1 : 611430,611699,624310, 541330,

541710, 611710 AND Pool 2: 541611, 541612, 541613, 541618, 611710, 541330,

541710, 541330, 541690, 541614


amended.

NAICS

Section G.2.4, paragraph three, line item four, states, “Issuing task order solicitations

under the proper NAICS Code and corresponding HCaTS Contract Number (See

Section H.4 (NAICS)).” Does a contractor have to have an on-file NAICS code that

matches the one selected by the Ordering Contracting Officer (OCO) in order to

respond to a task order?

No. NAICS

60

Recommand: 1) H.1.4: Add 541910 to the list of Pool 2 NAICS codes. GSA provides

a list of NAICS codes in each contemplated pool. While we certainly agree that

HCaTS relevant work could be conducted under any of the currently listed NAICS

codes, we find this list to be incomplete. More specifically, our firm has conducted

substantial research (and related consulting) under NAICS code 541910 to support a

number of KSA’s within the HCaTS scope including research on work life balance,

performance measurement and reporting, and recruitment and outreach. As such we

urge GSA to add 541910 to the list of HCaTS SB NAICS Codes specified in H.4.1.


amended.

NAICS

L.5.2, We recommend that NAICS requirements for past performance credentials be

removed. The combination of NAICS and KSA requirements for each pool in the past

performance section is overly complex and confusing. As both the NAICS and KSA

requirements are similar in their relation to the type of services provided over the

course of a contract, only one set of requirements is needed. Any types of services

reflected in the NAICS requirements but not the KSA requirements could be added

into the latter. The simplification would reduce the risk of qualified vendors submitting

non-compliant RFP responses, and would enhance HCaTS PMO ability to review and

award contracts to the most qualified Offeror.


amended.

NAICS

H.4.1 Suggest that NAICS codes should determine size standard at the TO level and

should not be mapped to KSAs at IDIQ level.


amended.

NAICS

NAICs codes should only be used to determine the bidder’s size standard and not to

define scope or as a criterion for past performance. They should be applied at the

task order level. Clear guidance is also needed impacting how NAICs codes applied

to IDIQ contracts and schedules are applied.

A Relevant Experience Project's NAICS Code that is from a task

order that is off of an IDIQ contract, will be determined based on

the NAICS Code that the task order was awarded under.

NAICS

H.4.1 Please clarify the NAICS codes for all current and previous work

performed under the existing OPM/TMA contract. Also, please clarify whether

the IDIQ NAICS codes or Task Order NAICS codes (unassigned at this time)

can be used and when (i.e., specific dates) such assignments would be

applied to existing / previous task orders. These clarifications are critical

since the current DRFP language would render much of an offeror's existing

OPM / TMA past performance as ineligible or unacceptable, even though the

work is highly relevant to human capital and training key service areas.

The current OPM contract vehicle assigns NAICS Code 541611 to

all task orders. Under HCaTS, the Ordering Contracting Officer will

choose the appropriate NAICS Code that makes up the

predominant amount of work at the task order level and award

under that specific NAICS Code.

NAICS

61

J.10 appears to be asking the Contracting Officer to make a re-determination of the

appropriate NAICS code for the work performed under the cited contract; an action

which is not legally permissible. By regulation, the contracting officer is required to

“determine the appropriate NAICS Code and related small business size standard

and include them in solicitations.” 48 C.F.R. (“FAR”) 19.303(a)(1). Thus, the required

time for determining the applicable NAICS Code is at the time of solicitation, 13

C.F.R. 121.402(b), not after contract award. The NAICS code assigned to a

procurement, and its corresponding size standard, is final unless timely appealed to

SBA's Office of Hearings and Appeals. FAR 19.303(c); 13 C.F.R. 121.402(d).

Question: Are you asking the Contracting Officer to make a determination to

CHANGE the NAICS from what was originally assigned?

Attachment J.10 NAICS Code Confirmation form will be amended in

the final RFP to state that this redetermination is solely for the

purposes of the evaluation of HCaTS and any redetermination will

not require of the Contracting Officer to take any action or make

any changes in the original contractual documents or how it was

reported in PPIRS and FPDS-NG.

NAICS

J.10 appears to be asking the Contracting Officer to make a re-determination of the

appropriate NAICS code for the work performed under the cited contract; an action

which is not legally permissible. For the HCaTS RFP, the only issue at-hand is an

inaccurate reporting in FPDS of the correct and original NAICS Code assigned to the

contract/task order cited as past performance at the time of its solicitation, not a re-

determination of the NAICS Code. These solicitations/contracts are a matter of public

record and easily verified. There should be no need for a warranted Contracting

Officer to be involved or to certify. Question: Would you consider requiring Offerors

who have a past-performance contract citation with a NAICS Code that has been

incorrectly reported in FPDS to submit the page(s) from the original solicitation and/or

contract which reflects the correct NAICS Code vs the one inaccurately reported in

FPDS?

Yes. The RFP will be amended allowing Offerors to submit

contractual documents to substantiate NAICS Codes. In addition,

the RFP will have an order of precedence so Offerors know which

documents we will consider over others. For example, if FPDS-NG

has a different NAICS Code than the contractual documents, the

NAICS Code identified in the contractual documents will be used.

On the Self-Scoring Worksheet (J.5.1 and J.5.2), the Offeror will

select the document that is validating the NAICS Code based on

the order of precedence.

NAICS

Are offerers required to provide products/services for all HCaTS SB NAICS Codes

associated with the pool they are submitting a RFP response to, or is providing

products/services only for certain NAICS Codes acceptable?

Yes, an Offeror only needs to submit Relevant Experience Projects

in one Pool NAICS Code in the Pool(s) that they are applying for.

Four Relevant Experience Projects must have been performed in a

Pool NAICS Code, but they are allowed to all be for the same Pool

NAICS Code.

NAICS

We remain strongly opposed to the use of NAICS codes as experience-based

screens associated with the general HCaTS contracts—we think they should be

associated exclusively with specific task orders. However, if NAICS codes as used as

proposed, we argue for replacing 541613 (Marketing Consulting Services) with

541720 (Research and Development in the Social Sciences and Humanities). In our

experience, 541720 better captures both the nature of the work performed under the

current TMA vehicle as well as the KSAs proposed under HCaTS.


amended.

NAICS

Regarding past performance, in section L.5.2 Volume II (Pool Application and

Certification) you require specific NAICS codes for four of six Relevant Experience

Projects. The recent OPM TMA contract and task orders received through it did not

have NAICS codes associated with them. Will work performed for Federal agencies

through OPM TMA count as past performance with the appropriate NAICS codes?

Will we be able to obtain a NAICS code for the projects we have performed through

OPM TMA?

Offerors have the opportunity to request a Contracting Officer

redetermine a NAICS Code using J.10 NAICS Code Confirmation

Form if the Offeror believes the originally awarded NAICS Code

was incorrect. In addition, NAICS Codes can also be substantiated

through the PPIRS Report, Past Performance Substitute Form and

additional contractual documents.

NAICS

62

H.4.1 Would the government consider removing NAICS codes from bid

requirements, and not awarding additional points for NAICS, as they are not relevant

to the work performed, and used for no other reason than industry reporting?

Justification/Reason/Explanation: Placing importance on an offeror’s NAICS code as

opposed to the actual key service areas delivered results in the government

evaluating a factor (NAICS codes) that is immaterial. Further, using NAICS codes as

a pool qualification requirement may restrict highly qualified offerors from bidding or

presenting their most relevant projects for evaluation. For example, work performed

under the current OPM TMA bridge contract is reported in FPDS under NAICS

511210, which is not associated with either HCaTS pool. Eliminating NAICS codes for

pool qualification and evaluation will allow offerors to submit their most relevant

projects and for the government to evaluate

those projects. Instead, we recommend the government evaluate projects according

to the key service areas performed, and enable additional points for performing

multiple KSAs. We recommend the government remove any evaluation or additional

points relating to NAICS codes.

The RFP will be amended removing the additional scores assigned

to NAICS Codes.

NAICS

Do the Offeror’s Past Performance to satisfy the NAICS requirements, have to been

the same Past Performance entries supplied for the cross-walk to the KSAs and

additional points related to contract value and duration?

All Relevant Experience Projects must meet the minimum

requirement. One of the minimum requirements is that the contract

or task order represent at least one KSA. However, only four

Relevant Experience Projects must have a Pool NAICS Code.

NAICS

Please reconsider the decision to give offerors extra points if they can present

contracts in more than one NAICS. NAICS do not reliably represent the type of work

done on a government contract, and the decision to use a NAICS for that purpose is

arbitrary.

a. Contracting officers can assign one and only one NAICS to any award.

Contractors are asked to present complex, multidisciplinary projects to compete for

HCaTS. Because only one NAICS can be assigned to those projects, some of the

activity in those projects will necessarily not be shown. b. Furthermore, NAICS

assignments are sometimes wrong, as SBA's size standard protest cases show, and

frequently arbitrary, as academic work in government contracting as shown (see

http://acquisition.gov/COMP/aap/documents/Chapter7.pdf, page 442, finding 7,

showing that a large number of Defense procurements had been incorrectly classified

as "soybean farming" in FPDS-NG, because the NAICS code for soybean farming is

the first in the NAICS code list).

We appreciate that GSA has offered contractors an opportunity to request COs to

"correct" the NAICS assigned to their contracts, but COs are not required to do so.

Changing a NAICS is administratively burdensome and in some cases would cast into

question the basis for a small business set-aside, so this remedy does not provide a

meaningful resolution of the issue.

This scoring element has been removed from the final RFP. NAICS

63

Section L.4.1, L.5.1.9.2. The proposal format table lists SAM registration as a file

(ABC.VOL1.SAM.pdf) in volume 1. What specifically is to be included in this file?

Are you asking for a printout of all sections of the Offeror's SAM registration? The

referenced section L.5.1.9.2 just states that, "For each Pool applying for, the Offeror’s

System for Award Management (SAM) representations and certifications shall include

the predominant NAICS Code (611430 and/or 541611)."

Yes, Offerors shall submit their full SAM record, with the SAM

record having at a minimum the predominant NAICS Code under

the Pool applying for.

NAICS

Is it necessary to use both a Pool (H.4.1) and KSA structure (C.1.1; C.3.1; C.3.1.2;

C.3.1.3when agencies frequently use the most general NAICS codes in the HR/HCM

area, particularly for larger tasks that encompass multiple NAICS code areas? Would

the Government consider simplifying the final RFP by using the KSA groups and

removing the Pools?


amended.

NAICS

NAICS/KSA Requirements (L.5.2): We recommend that NAICS requirements for past

performance credentials be removed. The combination of NAICS and KSA

requirements for each pool in the past performance section is overly complex and

confusing. As both the NAICS and KSA requirements relate to the type of services

provided over the course of a contract, only one set of requirements is needed. Any

types of services reflected in the NAICS requirements but not the KSA requirements

could be added into the latter. The simplification would reduce the risk of qualified

vendors submitting non-compliant RFP responses.

We anticipate under both contract vehicles Offerors submitting one

proposal under both Pools. Requiring Offerors to have at least four

Relevant Experience Projects with an associated NAICS Code from

the Pool applying under will reduce the possibility of the same

Offerors winning under both Pools. Therefore, under the

Unrestricted Contract Vehicle, mid-sized companies have a better

chance of having a contract awarded, and under the Total Small

Business Set-Aside Contract Vehicle the very small companies

have a better chance of having a contract awarded.

NAICS

H.4.1 In Pool 1, NAICS codes 611699 and 624310 are subsets of 611430. If the

government includes and assigns points to these subset NAICS codes, they will be

providing an unfair advantage to niche training vendors. This will put companies

providing full-service training capabilities at a disadvantage; this seems contrary to

what OPM would want and what would be in the best interest of this contract. We

suggest that GSA remove NAICS codes 611699 and 624310 as they are merely

subsets of 611430.

The scoring element tied to NAICS Codes will be removed from the

RFP.

NAICS

64

L.2.4, L.5.2, and M.7 This potential offeror has concern with the use of the separate

NAICS codes and their application to the past performance evaluation criteria. There

are several reasons for our concern.

(1) According to the United States Census Bureau, the North American Industry

Classification System (NAICS) is the standard used by Federal statistical agencies in

classifying business establishments for the purpose of collecting, analyzing, and

publishing statistical data related to the U.S. business economy. The generally held

opinion is that the NAICS categories and definitions were not developed to meet the

needs of procurement and/or regulatory applications. This is evidenced by the fact

that companies select their own NAICS codes based on the work they perform. There

is no central government agency with the role of assigning, monitoring, or approving

NAICS codes for establishments. Individual establishments are assigned NAICS

codes by various agencies for various purposes using a variety of methods.

Therefore, the idea of assigning evaluation points on a major competitive

procurement based on the use of a system that is applied through a variety of

methods is extremely concerning and highly subjective.

(2) The application of points for having multiple NAICS codes on relevant projects

could unjustly penalize offerors. Often, work can easily fall under several NAICS

codes. For example, a task order performed under NAICS code 541611 could also

encompass work that falls under 541618. Assume that an offeror holds an ID/IQ

contract under NAICS code 541618, and that contract has numerous task orders

competed on it. The contract and task orders themselves are relevant to HCaTS and

the KSAs. However, the contracting officer may have chosen to simply use the

NAICS code for the main contract on the individual task orders, even if the work

entailed on the task order could fall under other NAICS. In this scenario, if the offeror

were to use these past projects as relevant references, they will garner as many

evaluation points as they would if the contracting officer had selected different NAICS

codes for the task orders. This penalizes the offeror for a decision made by a

previous contracting officer.

The scoring element tied to NAICS Codes will be removed from the

RFP.

NAICS

65

(3) The DRFP states, “The NAICS Code shall be validated by either the past

Performance Retrieval System (PPIRS) Report or Attachment J.6 (Past Performance

Substitute Form).” If there is no PPIRS report and no completed Attachment J.6, “the

Federal Procurement Data System-Next Generation (FDPS-NG) Report shall be used

to validate the NAICS Code. However, this offeror has examined their own PPIRS

and FPDS reports and has found conflicts between the two. Therefore, there is not a

reliable form of verification.

(4) There is a stipulation in the DRFP that is meant to provide an offeror with an

avenue to correct an incorrectly reported NAICS code. However, a contracting officer

is required to sign a letter stating that they incorrectly reported a NAICS code. It is our

opinion that contracting officers will not do this. In most instances, it won’t be a case

of an incorrect NAICS, but more likely a case of more than one applicable NAICS

code. We suggest one of four methods to allow GSA and OPM to ensure they fairly

and objectively rate and score past performance and relevant work.

1. Remove the use of NAICS codes in the assignment of points for past

performance. The primary concern of the government should be on successful

performance of relevant work. This can be done by requiring a mapping of the actual

work performed to the work required by the HCaTS solicitation.

2. Allow offerors to self-certify their relevant experience projects under one of the

NAICS codes listed in L.5.2. In this case, the government could require a brief

explanation as to applicability of the selected NAICS code.

3. Allow a letter from a contracting officer that states the applicable NAICS code for a

relevant project, without requiring the contracting officer to declare the initial NAICS

code to be incorrect.

4. Award substantially more points for the predominant NAICS code in each Pool.

The RFP will be amended to state the order of precedence in

establishing the NAICS Code for the contract or task order if there

is a discrepancy between, PPIRS, FPDS-NG, and Contractual

Documents. The order of precedence is first the contractual

documents, FPDS-NG Report, PPIRS Report. If the Offeror has

the Contracting Officer use J.10 NAICS Code Confirmation Form,

then that will be the document that determines the NAICS Code.

The language in the final J.10 will be amended to state that the

NAICS Code determination is solely for evaluation purposes for

HCaTS and does not change any official contractual documents nor

reports.

NAICS

66

• Reduce the Number of NAICS Code Restricted Projects to Two or Three. Draft

RFP Section L.5.2 requires that “the Offeror shall have performed six Relevant

Experience Project, with four of those Relevant Experience Projects under a NAICS

Code that corresponds directly to a NAICS Code in the Pool being applied for…”

GSA and OPM have received ample feedback from industry that NAICS code are not

a valid indicator of the nature of work performed and thus potentially misleading.

Entire contracts routinely use a common NAICS code regardless of the specific

nature of the task orders issued. This is the case for the OPM TMA vehicle currently,

even though some task orders under that contract would be more accurately

classified under other NACIS codes. NAICS codes are assigned by Contracting

Officers but do not necessarily reflect the totality of the work performed or even the

primary focus of the work, especially on larger, longer-term projects that have evolved

over time to meet changing agency requirements. Thus, GSA and OPM know in

advance that an overreliance on NAICS code as a defining requirement/structure of

the RFP is fundamentally misleading and distorting to the competitive process.

Reducing the number of “Relevant Experience” projects having a NAICS code

corresponding to one of those listed for that Pool to two or three would minimize this

distortion and allow for greater competition. As GSA itself as noted, the KSAs

provide a better basis for evaluating the relevance and applicability of a given project

than the NAICS code.


amended.

NAICS

(Section M.6.3), p. 140 What are the NAICS codes for the full-and-open compete?

They are the same as the NAICS Codes under the Set-Aside

Contract Vehicle

NAICS

67

NAICs and the Evaluation Methodology

We oppose the NAICs code point scoring system for Relevant Experience Projects.

The basic procurement purpose of NAICs is to determine an offeror’s size status not

to evaluate the relative quality of proposals. Using the NAICs for evaluation purposes

emphasizes form over function. It is merely a number crunching exercise that is

dependent on the vagaries of past NAICs assignments to contracts across the

Federal enterprise. Experience shows that assignment of NAICs to contracts is often

an arbitrary, paperwork exercise reflecting agencies’ understanding of the process

and its reporting needs. As such, the data on NAICs is not reliable for evaluation

purposes. Although a NAICS Redetermination form has been included in Section J,

we do not believe that it is appropriate to request contracting officers to reassign

NAICS codes for purposes of a source selection evaluation under another

procurement. In addition, use of NAICs in the evaluation presents the following

challenges and/or anomalies: There are multiple NAICs well beyond those currently

identified in the DRFP that have been assigned to work corresponding to the

Knowledge, Skills and Abilities (KSAs) identified in Section C. As a result, offerors

with work corresponding to the KSAs but assigned a NAICs outside the DRFP are at

a disadvantage. Moreover, it limits access to potentially relevant work that OPM

should consider in seeking contractors that can best meet customer agency

needs.Different NAICs were and have been assigned to the previous TMA contract

and the current bridge contract than those listed in the DFRP. As a result, offerors

who performed work directly corresponding to KSAs under OPM’s prior contract

vehicle are competitively compromised. Commercial work corresponding to the KSAs

is at a disadvantage relative to work for the Federal Government. This disadvantage

is reflected in the requirement to have the commercial customer address the

applicable NAICs as part of the waiver form provided in the DRFP. It is an additional

administrative burden tied to submission of commercial projects for evaluation

purposes. Theoretically, accepting GSA and OPM’s rationale that the NAICs listed in

the DRFP reflect the work being performed more so than use of the KSAs amounts to

double counting relevant experience in a manner that adds no true relative value to

the evaluation of proposals. The overarching goal of all procurements is to acquire

the products, services and solutions to meet the needs of customer agencies and,

ultimately, the American people. Section C of the HCaTS DRFP sets forth the KSAs

Points associated with NAICS Codes will be removed from the

RFP.

NAICS

Commercial Past Performance - We appreciate GSA’s efforts to allow credit for

commercial past performance through the addition of the Past Performance

Substitute Form in Section J. However, the DRFP still has barriers to the inclusion of

commercial past performance due to the bureaucratic nature of the form. Offerors

must have their commercial customers certify to the applicable NAICS code and

assess their work in areas that do not necessarily apply to the commercial market. An

example is “Utilization of small business” which references specific small business

categories relevant to the Federal market. Further, the form does not include a

description of the NAICS codes. As a result, HCaTS still favors government work

largely because NAICS codes are driving the scope of the contract. Rather than

requiring commercial customers to certify to specific NAICS codes, the Coalition

recommends that past performance be tied to the KSAs in order to increase

innovation and competition.

The RFP will be amended to include a description of the NAICS

Codes. We disagree with your interpretation that NAICS Codes are

driving the scope. Rather, we chose the NAICS Codes that most

appropratialy fall within the KSAs. All past performance is tied

solely to the Relevant Experience Projects, which need to be

inclusive of at least one KSA. Requiring at least four Relevant

Experience Projects match at least one of the NAICS Codes

reduces the risk of very large companies winning contracts under

both Pools.

NAICS

68

The solicitation rewards firms with relevant experience in more than one NAICS

code, but intends to categorize all work under the contract by one of 2 predominant

NAICS codes. TMA vendors will be disadvantaged by the fact that ALL TMA work is

recorded in FPDS as 611430 (training), regardless of which side of the vehicle the

TO was completed on

• Companies get up to 400 bonus points for having more than one NAICS code.

For many IDIQ contracts (including TMA), the same NAICS code is used for every

task order. Because of this, companies could be missing out bonus points if they use

multiple TMA task orders as past performance. Conversely, the largest federal

contractors (Booz, Lockheed, etc.) would have the greatest chance of receiving the

400 points just based on the volume of contracts they could choose from.

• Additionally, all of the task orders on the original TMA contract (including work

on the Human Capital key service area) were coded with 611430 (Training). Because

the original TMA solicitation listed 541611 as the primary NAICS, we believe that this

code has been erroneously applied to Human Capital task orders. Since 611430 is

the primary NAICS for Pool 1: Training/Learning, this error would prevent us from

using these TMA task orders as past performance for Pool 2: Human Capital.


• Remove the bonus points associated with multiple NAICS codes, while keeping

in place the bonus points associated with multiple KSAs. This ensures breadth of

experience in projects directly relevant to HCaTS, while removing the competitive

barrier for mid-size companies and TMA incumbents.

The RFP will be amended removing points earned for NAICS

Codes. The Contracts will be awarded under the predominant

NAICS Code, but the Task Orders may be solicited and awarded

under any of the Pool NAICS Codes that are in the Pool that it was

released under.

NAICS

Section L.5.2.3.3 on pg. 119. “In addition, for each Pool applied for the Offeror will

receive additional points if the cumulative of all Relevant Experience Projects

exceeds one validated Pool NAICS Code. Points will be applied in a tiered system

that increases with the number of additional validated Pool NAICS Code(s)

represented.”

NAICS code does not necessarily mean that the work performed is directly relevant to

the HCaTS KSAs. Additionally, all of the task orders on the 2007 TMA contract

(including work on the Human Capital key service area) were coded with 611430

(Training).

Will the government consider removing the bonus points associated with multiple

NAICS codes, while keeping in place the bonus points associated with multiple

KSAs? This ensures breadth of experience in projects directly relevant to HCaTS,

while removing the competitive barrier for mid-size companies and TMA incumbents.

Points associated with NAICS Codes will be removed from the

RFP.

NAICS

69

Would the Government consider adding NAICS code 511130 (Publishing) to the

RFP?

Due to the large amount of training workbooks likely to be purchased through this

vehicle we thought we would ask. In many of the training contracts we have delivered

on over the last 20 years the overall cost of the student workbooks is significantly

higher than the services to design and deliver the training itself. We are seeing more

and more solicitations being released under the 511130 NAICS instead of 611430.


amended.

NAICS

Will the government allow more than two relevant experiences outside of the NAICS

code pools?

Offerors are permitted to have no more than two Relevant

Experience Projects per Pool not match one of the eight NAICS

Codes identified in the DRFP.

NAICS

In lieu of tying past performance to the performance of functions under a limited

number of NAICS codes, GSA and OPM should eliminate the NAICS code

requirement for eligible past performance and evaluate offeror eligibility and past

performance relevance tied only to the KSAs.

Past performance is tied solely to the Offeror's performance of a

project that is inclusive of at least one KSA.

NAICS

If GSA and OPM insist on retaining the NAICS code approach to determining

eligibility, then the number of NAICS codes listed in each pool should be significantly

increased so that those with clearly relevant and successful experience not be

unfairly disadvantaged. For example, GSA and OPM should consider relying on the

four digit NAICS codes, not the six digit NAICS codes, in each pool. As stated above,

PSC recommends that eligibility and past performance be based on the performance

of the KSAs, and not the short list of NAICS codes included in the Draft RFP.

The chosen NAICS Codes reflect what future task orders'

predominant work may be under the scope of HCaTS.

NAICS

GSA must clarify, and preferably provide examples of, how non-federal projects here

the offeror self-certifies the NAICS code will be scored.

Because the commercial sector does not have an FPDS or PPIRS

equivalent systems, and if no Past Performance Substitute Form is

completed, Offerors are permitted to self-certify non-Federal

projects. We recognize that this cannot be done for federal

projects, which is a contributing factor in federal projects having

additional points assigned to them.

NAICS

4. Page 47 and 48 of 144 . . . H.3 Ordering Procedures reads . . . “All task orders

under HCaTS contracts shall: . . . Be solicited and awarded under the proper NAICS

Code and corresponding Contract Number (see Section H.4 (North American Industry

Classification System)

Comments/Suggestions: The NAICS code system is very subjective. Who, within the

government, will be responsible for determining the “proper” NAICS code?

A duly warranted Contracting Officer that awarded and/or

administered the contract or task order.

NAICS

70

5. Page 48 of 144 . . . H.4.1 HCATS NAICS CODES provides the following table

. . . Comments/Suggestions: The work required under HCaTS (and its predecessor

TMA) is expansive. The government is looking for contractors that provide expansive

capabilities as demonstrated in the KSA listing, yet GSA has included NAICS codes

that are very narrow in scope.

For the past 15 years or so, this work was typically classified under NAICS codes that

were more general in nature (e.g., 541611 Administrative Management and General

Management Consulting Services). By including such narrow defined NAICS, the

government will run the risk of securing niche companies that do not necessarily

provide the depth of capability required to meet the government’s needs but can

check the box.

These NAICS codes actually limit competition rather than increase it. Further, the

government states on page 3 of 144 B.1.1 Office of Personnel Management . . . “In

all cases, the project deliverables are customized or designed to meet unique agency

specific requirements that cannot be adequately met through the use of off-the-shelf

solutions.” Yet, the NAICS code 611699 All Other Miscellaneous Schools and

Instruction is typically used to secure off-the-shelf solutions.

NAICS codes are archaic and have not been updated and do not reflect the changing

marketplace from manufacturing to knowledge-based economies. For example, there

is no NAICS for online learning. These services are classified under 541611

Administrative Management and General Management Consulting Services instead

of Software Publishing. By definition the contracts have the wrong NAICS.

Additionally, NAICS code selection process is subjective and random. Government

contracting officers are using NAICS to classify Small Business Set asides, therefore

they are selecting NAICS that may not necessarily map to the services being

performed. For example, Air Crew training services are being classified under Flight

Services, rather than under education and training.

Under HCaTS procurement, contractors are being penalized for government’s errors,


amended.

NAICS

6. Page 49 of 144 . . . H.4.2 Predominant NAICS Code Determination states that

. . . “The OCO must identify the NAICS Code Number, Title, Business Size Standard,

and corresponding Pool in the task order solicitation and report the NAICS Code in

the Federal Procurement Data System-Next Generation (FPDS-NG) system.”

Comments/Suggestions: If the CO is going to determine the appropriate NAICS code

for an opportunity under HCaTS, why can’t they also review past performance and

contract documentation provided with our proposals to determine NAICS code

relevance? If the CO is going to determine NAICS during the operation of HCaTS,

why can’t they do it during the proposal review process? Many of our contracts could

have been coded differently and probably should have been. Why not let the

government review our past projects and rate them accordingly.

The Past Performance Substitute Form will be amended to allow

any Federal employee with knowledge of the Offeror's past

performance to rate the Offeror's Relevant Experience Project.

To ensure equitable treatment for all Offerors, the HCaTS team is

requesting that all information be included in the proposal by the

time the RFP closes.

NAICS

71

Comments/Suggestions: As follows are recommendations to allow GSA to ensure

they fairly and objectively rate and score past performance and relevant work.

1. Remove the use of NAICS codes in the assignment of points for past

performance. The primary concern of the government should be on successful

performance of relevant work. This can be done by requiring a mapping of the actual

work performed to the work required by the HCaTS solicitation.

2. Allow offerors to self-certify their relevant experience projects under one of the

NAICS codes listed in L.5.2. In this case, the government could require a brief

explanation as to applicability of the selected NAICS code.

3. Allow a letter from a contracting officer that states the applicable NAICS code

for a relevant project, without requiring the contracting officer to declare the initial

NAICS code to be incorrect. (To offer this option, consider the time the COs will take

to provide this letter and also the possibility that they may not be comfortable with this

approach)

4. Award substantially more points for the predominant NAICS code in each Pool

The RFP will be amended removing the additional scores assigned

to NAICS Codes; however, Offerors will still need to submit at least

four Relevant Experience Projects per Pool that map to a NAICS

Code prescribed in the RFP.

NAICS

What happens if the NAICS assigned to a First-Tier subcontract is not the same as

the NAICS assigned to the federal prime contract?

The RFP will be amended to allow the Prime Contractor to certify

the applicable NAICS Code for the work the First-Tier

Subcontractor performed on J.6 Past Performance Substitute Form.

The First-Tier Subcontractor's NAICS Code does not have to be the

same as the Prime Contractor's NAICS Code. The First-Tier

Subcontractor's NAICS Code is determined based on the work that

they performed and not the entire scope of the Prime Contractor's

Contract.

NAICS

Page 70, Section H.2.3.1, Lateral Pool On-Ramping – It makes sense to require small

businesses that will hopefully be growing under the HCaTS vehicle to recertify their

size standard. However, what does not make sense is how a small business that is

awarded a contract under Pool 1 (training) can be expected to move to Pool 2

(human capital) if their capability and relevant past experience is in training, not

human capital? While the size standards are different, the type of work and relevant

experience are vastly different. Please clarify how this makes sense. Size standard

is based on a 3 year average of revenues. It would not make sense to recertify every

year, but perhaps every 2-3 years to make sure the 3 year average is still within the

NAICS code size standard

An Offeror need not have performed previous work in every KSA to

have been awarded a contract in any Pool. Furthermore, both

Pools consist of the same three KSAs and scope (Section C).

On-ramping

L.5.3.4 CPARS sometimes/often include an overarching score. Recommend

permitting the use of this score if it is present in place of the averaging method

provided in the DRFP.


amended.

Past Performance

If proposing as a single small business that has existed for around a year, will the

government accept personal past performance in lieu of or in addition to corporate?

No. Past Performance

72

Will the government accept past performance examples from prime offerors (the

offeror putting forward a bid for HCaTS) where services were performed for the

Federal Government as a subcontractor?






However, when submitting a proposal as a Joint Venture, all

Relevant Experience Projects and associated past performance

information shall have been awarded under the existing Joint

Venture's DUNS Number and not the individual members making

up the Joint Venture.

Past Performance

from Subcontractors

Can it be acceptable for Small Businesses to use teammates for Past Performance

when the teammate performed the reference as a Prime contractor? That would

satisfy the Government’s concerns for validity of the Past Performance and allow the

Small Business Prime to produce sufficient number of Past Performances to meet

HCaTS requirements. That is a win/win scenario for the Government and industry.







Past Performance

from Subcontractors

If a company is going to be a Prime Contractor on HCaTs and performed work as a

subcontractor on a contract with a Federal government entity, can this work be used

as Relevant Experience (i.e. prior subcontractor is now going to submit a bid as a

Prime and wants to use work they performed when they were a subcontractor as

Relevant Experience)?






Past Performance

from Subcontractors

HCaTS RFI FAQ p.13: We recommend that both prime and subcontractor past

performance credentials be considered in the Request For Proposal (RFP). Both the

prime and subcontractor can add value to the HCaTS PMO through their respective

experience. Attention should not focus on whom among the Prime or Subcontractor

has experience to fulfill the requirement, as long as the team as a whole has the

functional experience to successfully execute on HCaTS task orders. The prime

contractor should bring experience forming a team and managing it effectively while

subcontractors bring specialized technical experience that the prime contractor

cannot offer by themselves. Small businesses typically have specialized experience

and do not possess the wide breadth of experience the HCaTS RFP requires, which

is why they team with other businesses to supplement their base of experience.

Considering just the past performance credentials of the prime contractor will

unnecessarily obscure the fully body work/experience of the combined teams.

Recognizing the Subcontractor’s credentials as past performance would provide an

added level of detail to evaluators as they assess an Offeror’s value proposition.






Past Performance

from Subcontractors

In order to increase the quality and quantity small business primes, it would be in the

best interest of the government to permit small business primes to submit past

performance from their teammates where the teammate performed the past

performance as a prime. This would enable small businesses under the $11M and

$15M size standards to attain the requisite number of past performances and

diversity of past performances to meet the myriad of government requirements.


amended.

Past Performance

from Subcontractors

73

L.5.2 Will the Government consider modifying Section J.10 NAICS Redetermination

template to allow contract officers to validate the KSAs without having to change the

NAICS code? This approach is consistent with the requirement for non-Federal

Government Relevant Experience Projects for which the offeror may self-certify the

NAICS code.


amended.

Pools

RFI Question: OPM’s last answer states, “This requirement will apply to all Pools.”

Can OPM clarify whether “apply to all Pools” means that the statement would apply to

both Pools but each Pool separately or if the statement applies to both Pools but

across them comprehensively?

We are not sure what question you are referring to. Keep in mind

there have been many changes since the RFI.

Pools

H.4.1 Suggest eliminating pools for the unrestricted large business IDIQ and just

have one contract, making it less administratively burdensome for Industry to manage


amended.

Pools

L.2.4 For each pool listing, it states: “Maximum Number of Multiple Awards: 40” Is

this 40 for the Unrestricted contract only?








Pools

Align HCaTS awards under one contract. Awarding two separate MA-IDIQ task order

contracts will complicate the post-award HCaTS ordering process, increase

contracting actions, and artificially limit the ability of the government to issue single

task orders for services that span the proposed separate MA-IDIQ task order

contracts. We recommend the government structure HCaTS under one contract, with

two Pools (1. Training and Learning, and 2. Human Capital). Offerors could receive

an award in Pool 1, Pool 2, or both, and only awardees in both Pools would be

eligible to bid on requirements that include work from both pools. This is similar to the

current OPM TMA Bridge which is structured under one contract, with two Key

Service Areas (1. Training and 2. Human Capital). A single contract, with contractors

designated as qualified in one or both Pools, will provide agencies the flexibility to

issue single task orders to qualified contractors across the human capital and training

services life cycle (e.g. from planning, to assessing, to designing, to piloting, to

implementing, to testing, to operating, and to oversight). A single contract will also

benefit the government and contractors by reducing the number of potentially

unnecessary contract actions.


amended.

Pools

H.4.1 & K.1 Can the Government clarify why there are two pools described in the

Unrestricted draft solicitation? Aren’t the pools only applicable to SB participation?

If there were just one Pool, less companies would be eligible for

award. In addition, the two contract vehicles mirror each other's

structure for the customer's ease of use.

Pools

Section K.1 (Page 80) discusses the Pool structure for the HCaTS contract. With

regard to Pool 2, the Education Support Services NAICS code is not typically

delivered as part of general strategic human capital consulting. Will the government

consider removing the NAICS code, as the Pool would still be comprised of 4

appropriate NAISC codes for the size standard and type of services bring provide

under Pool?

Based on our market research, this NAICS Code will be used by

Ordering Contracting Officers for future task orders.

Pools

74

(Section M.6.3), p. 140 What happened to Pool 3? It is not mentioned in the draft

RFPs.

Pool 3 has been removed from the RFP Pools

Contract Duplication

We are concerned about the award of two separate sets of contracts (for both the

Unrestricted and Small Business contracts) corresponding to Pool 1 NAICs and Pool

2 NAICs rather than a single set of integrated contracts covering both Pools.

According to our conversations with GSA, the current structure results from an

inability of the Federal Government to implement the regulatory and systems changes

response to the Small Business Jobs Act of 2010. The unintended consequence is

unnecessary, costly contract duplication for small, medium and large business

concerns. Here, the HCaTS DRFP contemplates the award of 80 separate contracts

covering the two pools (40 awardees for each pool) rather than the award of 40

integrated contracts that include both pools on each awardee’s contract. The

duplicative contract structure resulting from the HCATs DRFP will increase

government and contractor administration and management costs; costs that will be

borne by customer agencies and the American people. The Coalition recommends

that the HCaTS DRFP be restructured to provide for the award a single set of

integrated contracts covering both pools. In this case, during the initial contract period

(the Coalition recommends a five year base), GSA and OPM should assign a single

NAICs contract vehicle that best corresponds to the overall work to be performed. For

example, the NAICs for the prior TMA contract could be used to ensure continuity of

expectations for government and industry. Subsequently, for the option period (the

Coalition recommends a five year option period), GSA and OPM assign/list the

appropriate NAICs corresponding to the two Pools thereby allowing customer

agencies to assign the appropriate NAICs to the work being performed under the task

order over the course of the five year option period. This approach will reduce

unnecessary, confusing and costly contract duplication. This approach will also

increase ease of use and will promote more effective implementation of integrated

solutions that meet customer agencies’ needs. It will also allow for a sound, phased

implementation of the regulations when the upgrades to the Federal Government’s

reporting systems have been made. Finally, it is consistent with the SBA’s comments

and observations regarding implementation of 13 3 CFR 121.402 governing the

assignment of NAICs to contracts and task orders. At the time of implementation, the

SBA noted that it would take several years to accomplish. Specifically SBA stated

that “While the change in NAICS code assignments will improve the reliability of the

We believe that the structure prescribed in the RFP treats all

Offerors equitably at the contract and task order level in a clear and

consistent manner, allowing the Government to determine the

business size at the contract level and task order level while

remaining in compliance with the SBA Final Rule, dated October 2,

2013.

Pools

The HCaTS unrestricted contract should eliminate the dual pool structure and simply

rely on one pool that combines all the NAICS codes from the two current pools into a

single NAICS code (at the $15 million level).

Everything else being equal, to do this would signifcantly reduce

the ability of "mid-size" companies from obtaining an award. Also,

companies with a size standard between $11 Million and $15

Million would be both small and large, depending on which NAICS

Code was chosen. Therefore, we would have to request a small

business plan at the contract level from these companies, only for it

to not be applicable for all task orders. Additionally, having the

same contract vehicle structure in both HCaTS and HCaTS SB is

more customer friendly.

Pools

75

H.19 Would the Government consider an alternative metric based on the number of

proposals submitted over time, for example six submissions prior to Option I?

Shouldn’t the goal of using this contract be to encourage companies to submit quality

proposals over time without potentially reducing the pool of qualified companies?




Post Award

Per Section H.3.1, is there an estimate (or minimum target) of approximately what

proportion of task orders is likely to be setaside for the specific socioeconomic groups

noted therein (e.g., 8(a), WOSB, etc.)?

No. That decision will be made by each individual Ordering

Contracting Officer.

Post Award

Section H.19, HCaTS SB (page 65) states that a minimum of 3 task orders or a value

of $1M is needed for assurance that the contractor can obtain exercise of Option 1.

Please justify these numbers given that the length of performance for the base period

has not been set. Our view is the numbers are reasonable for a base period of 4 to 5

years but not for a period of less than 4 years.




Post Award

The combined annual value threshold for avoiding off-ramping is biased in favor of

larger vendors. Section H.19 states that a contractor “shall attain a minimum of three

task order awards or a total task order estimated value of $1.5M…” prior to the

exercise of Option I under their HCaTS contract. We would argue for eliminating this

wording, or at the very least reducing the combined threshold (i.e., $750,000).




Post Award

Section B. 3 No indirect costs are authorized for ancillary costs and ordering

agencies may prohibit contractors from recovering the indirect costs of travel and

materials. How are contractors to recover indirect costs on time and material task

orders?

Contractors are required to propose costs and/or prices in

accordance with the task order solicitation. If the Contractor

believes that a cost is allowable, it will have to discuss the matter

with the Ordering Contracting Officer.

Post Award

E.1. Why will the HCaTS PMO’s acceptance of deliverables be required as well as

the ordering activity’s acceptance?

The HCaTS PMO will only inspect and accept deliverables that are

required at the contract level, not the task order level.

Post Award

F.2 Will the HCaTS PMO be able to terminate task orders as well as HCaTS

contracts?

No, the decision to terminate a task order is solely made by the

Ordering Contracting Officer who awarded it.

Post Award

F.4.1 Will BPAs be permitted on HCaTS? No, FAR Subpart 16.5 only allows orders to be issued against an

IDIQ.

Post Award

F.5.1 Will Service Contracts Reporting (PL 111-117) be required, and if so, at the

contract or task order level?

The Draft RFP includes Clause 52.204-15 in Section H. Post Award

G.3.2.1.1 3. Is the requirement for incentive or award fee data on fixed price

contracts included in error?

No, an Ordering Contracting Officer may decide to add these at the

task order level.

Post Award

H.15 Meetings states . . . “The HCaTS PMO may require up to four HCaTS Program

Management Review (PMR) meetings per year.” We suggest GSA clarify whether or

not these are IDIQ-level or Project-level meetings

The PMRs are at the IDIQ-level. Post Award

Section F.5, Performance Standards. This section refers to the Government’s ability

to inspect the Contractor’s HCaTS SB records. Will there be a separate records

retention policy designating a specific number of years to archive and store these

HCaTS records, or should Contractors simply follow standard Federal guidance

regarding Federal contracting records retention?

Contractors should follow standard Federal guidance regarding

contract record retention.

Post Award

Section H.24, Dormant Status. Will there be an interim procedure established to allow

a Contractor to reverse a finding of Dormant Status without resorting to the

Alternative Disputes Resolution (ADR) process? It seems logical to offer Contractors

a method to appeal a final finding of Dormant Status before resorting to ADR and

Ombudsman involvement.

No Post Award

76

Section B.2 (page 6) and Section G.2.4 (page 33) discuss the role of the Ordering

Contracting Officer (OCO). Will the HCaTS Contracting Officer provide assisted

acquisition for the HCaTS contract?

No Post Award

Sections B.3.4 and B.3.5 (page 11) reference pricing for travel and materials and

equipment, respectively. Does the government intend to allow contractors to charge

general and administration (G&A) fees on these items as part of their indirect costs?

If the task order solicitation allows it, yes. Post Award

Page 65, Section H.19, Minimum Task Order Awards or Est. Value – The government

appears to be holding the Contractor responsible for winning a minimum number of

awards under the HCaTS vehicle or else be removed from the vehicle. How is it fair

to the Contractor to attain a minimum number of awards when the decision to make

an award is not their decision? This is a big concern as there has been very little to

no task orders released or awarded under the current incumbent OPM-TMA contract

vehicle. How is the government going to ensure there is ample business for

Contractor’s to seek under the HCaTS vehicle to allow them the opportunity to be

successful in gaining a minimum number of awards? Wouldn’t it be a better incentive

to ensure appropriate competition at the task order level and require Contractors to

respond to a reasonable minimum number of task orders under the HCaTS vehicle

assuming there are task orders released? A minimum number of awards is not a fair

measure when the Contractor has no control over award decisions.




Post Award

Are there any OCI considerations between developing software for EPIC 2 and

performing the duties of the HCATS program?

We are unaware of any OCI issues at this time; however, at the

task order level Contractors will have to disclose any known OCI

issues to the Ordering Contracting Officer for their consideration.

Post Award

What will the process be to respond to solicitations under the HCaTS contract? Will

vendors only be able to respond to task orders released within their awarded Pool or

will

they be eligible to respond in other Pools? Will the process be the same under the

HCaTS Unrestricted and HCaTS Small Business contracts?

Based on their market research, Ordering Contracting Officers will

choose to solicit under one Pool under either the HCaTS or HCaTS

SB contract vehicle. Only those Contractors awarded in the chosen

Pool will be permitted to respond to a task order solicitation.

Post Award

Our understanding is that the PPIRs database only holds CPARS for 2-3 years,

however, we are asked to provide contracts that have been active within the last 5

years. Can we confirm that we may provide CPARS for projects that are within the 5

year span, but due to restrictions are no longer in the PPIRs Database, for which we

have internally kept records.

Yes. The Final RFP will reflect this. PPIRS

If the offeror has a past performance reference that is documented in CPARS, but not

linked to PPIRS, can the offeror submit a copy of the CPARS rating information in

place of PPIRS? Would the offeror still be required to submit Attachment J.6?

If the CPARS report is older than 3 years and is no longer available

in PPIRS, the CPARS report may be submitted in lieu of the PPIRS

report.

PPIRS

If interim ratings are available in CPARS must the offeror still submit the past

performance substitute form?

If the PPIRS report is older than 3 years and is no longer archived

in PPIRS, the CPARS report may be submitted in lieu of.

PPIRS

77

L.5.3 VOLUME III (PAST PERFORMANCE FOR RELEVANT EXPERIENCE

PROJECTS) For each Relevant Experience Project submitted, Offerors are strongly

cautioned that inability of the Government to contact past performance references

directly associated to any survey; or, in the case past performance information is not

entered into the Past Performance Information Retrieval System (PPIRS) database;

or, in the case of Relevant Experience Project(s) without a record of past

performance, the Offeror will not be evaluated favorably or unfavorably on past

performance. Will OPM TMA incumbents' Past Performances be entered into

CPARS?

We recommend you contacting your OPM Contracting Officer to

discuss the status of your past performance report.

PPIRS

Section M.6.2. Regarding past performance, the solicitation provides that, “[i]f the

combined average is 2.99 or below, the Offeror will fail the Acceptability Review and

shall not be considered for award.” How does the Agency square this provision with

the statutory requirement that offerors without relevant past performance must be

treated neutrally?

An Offeror is permitted to submit a Relevant Experience Project

without past performance information and have it count to meet the

minimum requirements. If the Offeror submits a Relevant

Experience Project without a CPARS or PPIRS Report and the

Government finds one, that Relevant Experience Project will be

evaluated with the existing CPARS or PPIRS Report. For example,

if an Offeror submits a Relevant Experience Project without a

PPIRS, and the Government find the current PPIRS Report that

reflects an average score that is 2.99 or less, the Relevant

Experience Project will not be considered.

PPIRS

Section K.2.3 (d): “The offeror shall post the information in paragraphs (c)(1)(i)

through (c)(1)(iv) of this provision in FAPIIS as required through maintaining an active

registration in the System for Award Management database via

https://www.acquisition.gov (see 52.204-7).”

Section G.3.7: “Subject to FAR 52.209-9, the Contractor shall update the information

in FAPIIS on a semi- annual basis, throughout the term of HCaTS SB.”

- What corrective action can a contractor take if none of its Relevant Experience

contract-data appears in FAPIIS, but required SAM and CMR entries have been

completed by contractor?

Offerors are encouraged to reach out to a Government Assessing

Official to complete the Past Performance Substitute Form. If no

CPARS/PPIRS Report or Past Performance Substitute Form is

available, a Relevant Experience Project can still be submitted and

counted if it meets the minimum requirements.

PPIRS

How will the government resolve discrepancies between PPIRS and FPDS-NG? The RFP will be amended to reflect the order of precedence for the

NAICS Code determination. In this instance, FPDS will hold

precedence.

PPIRS

L.5.1.3 Will the Government consider removing the page limit from the Professional

Employee Compensation Plan for companies that have current plans approved by the

companies’ executive management/boards?

Yes. The RFP will be amended to remove page limitations for the

Professional Employee Compensation Plan and Uncompensated

Overtime Plan.

Professional

Compensation

F.5.1 H.9 and H.10 require vendors to notify the HCaTS PMO within “5 calendar days

of substitution” for Professional Employees Compensation and Uncompensated

Overtime Policy.” Does this mean within 5 calendar days of adoption of new policies?

Yes. Professional

Compensation

78

1. Page 117 paragraph 4 states,

“Only one Relevant Experience Project shall be submitted and considered per Pool if

awarded in accordance with FAR Subpart 6.3, FAR Subsection 8.405-6 or FAR

Subparagraph 16.505(b)(2).”

My interpretation of this verbiage is that an award of this type negates the

requirement for multiple experiences – replacing it with a sole experience. Could you

please confirm that this is true? Assuming it is true, how does this impact scoring?

This restriction has been removed. Relevant Experience

Projects

2. Relevant experience / past performance: Must all experience/past performances

be that of the prime contractor (company submitting the bid in which they were the

prime contractor) or is experience/past performance of team members/subcontractors

- provided the experience submitted is one in which the team member/ subcontractor

was the prime contractor - acceptable?











Relevant Experience

Projects

3. Could you please confirm that for contract awards that have option years, the

award of an option year constitutes a separate project?

No, option years do not count as separate projects. Relevant Experience

Projects

79

REFERENCE: Section M.4.2.1 of the HCaTS Unrestricted DRFP states, “The

Offeror’s Relevant Experience Projects well be initially evaluated on a pass/fail basis

in regards to meeting the minimum proposal submission requirements in Section

L.5.2.” The fourth paragraph of Section L.5.2 states, “A Relevant Experience Project

is defined as a single contract; or, a single task order placed under a master Single

Award or Multiple Award Indefinite Delivery, Indefinite Quantity (SA/MA IDIQ) task

order contract (FAR Subsection 16.501-1); or, single task order placed under a

Federal Supply Schedule (FAR Subsection 8.405-2); or, a single task order placed

under a master Single Award or Multiple Award Blanket Purchase Agreement (SA/MA

BPA) (FAR Subsection 8.405-3 or FAR Subsection 13.303). In order for a single

contract and/or task order to be considered as a Relevant Experience Project, the

Contractor shall have provided a service(s) in accordance with the terms and

conditions of the single contract and/or task order. Single contracts and task orders

with no performance of a service(s) shall not be considered. If a single contract has a

task order(s) awarded against it, the Offeror shall submit either the single contract or

the task order(s) as the Relevant Experience Project, but not both. If the Offeror

submits the single contract and the task order(s) awarded against it, the single

contract and the task order(s) shall not be considered.”

QUESTION: Neither DRFP Sections M.4.2.1 or L.5.2 place any age restriction on an

Offeror’s Relevant Experience Projects. Is it the OPM and GSA intent to allow

Offeror’s to submit experience projects otherwise meeting all relevancy submission

requirements regardless of age?

In accordance with L.5.2 Each Relevant Experience Project shall:

2. Have been completed within the past five years prior to the

solicitation closing date; or, be ongoing.

Relevant Experience

Projects

For businesses under the $11 million size standard for pool 1, it is unreasonable to

expect a contractor of that size to have performed on six relevant PRIME contracts

within the past 5 years, and to further expect that four of the six will be under a

specific NAICS codes. For training specifically, there are numerous training tasks

representing the full lifecycle of Customized Training and Development Services that

are integrated within larger programs. By their nature, they may be subcontracted,

and may fall under NAICS codes that represent the larger program rather than the

training-specific tasks.

Both Federal government and Non-Federal government experience

are accepted. Furthermore, an Offeror may submit a Relevant

Experience Project that they performed as a First-Tier

Subcontractor to the Federal government.

Relevant Experience

Projects

By placing such restrictive limitations on the viable past performance that can be

used, the government is automatically eliminating numerous highly qualified firms with

extensive, highly targeted, relevant experience. For SB pool 1 with a size standard of

$11 million, in order to ensure that the government is given the opportunity to

evaluate a larger pool of highly qualified firms, we respectfully request that you

consider accepting past performance as a subcontractor to fulfill the past

performance requirements.











Relevant Experience

Projects

80

We also respectfully request that you consider accepting a larger percentage of the

past performances from alternate NAICS codes, as many of the highly relevant

training tasks are classified under unrelated NAICS codes as part of the larger

program.

The reason why the Government is requiring Offerors to have at

least four Relevant Experience Projects per Pool map to one of the

prescribed NAICS Codes is to reduce the probability of Offerors

winning awards in both Pools without showing a breadth of

experience.

Relevant Experience

Projects

When submitting information as a contractor, should we also submit the sub-

contracting information if the submitted information based on experience and

education and not pass performance?

The scoring elements for the Relevant Experience Projects do not

take into account the education or experience level of the Offeror

nor their subcontractors. The Offeror will only need to substantiate

the scoring elements with supporting contractual and past

performance documentation.

Relevant Experience

Projects

The government provides the option to include a single contract with task orders

awarded against that contract as one Relevant Experience Project so long as the task

orders are not also submitted as a Relevant Experience Project. Can the government

confirm that Offerors may use the combined awarded task orders under one master

contract as one Relevant Experience Project to demonstrate the KSAs, duration, and

dollar value so long as the Offeror does not separately submit one of the Task Orders

as a separate and distinct Relevant Experience Project?

One Relevant Experience Project may be a collection of six or less

task orders awarded under a master contract or BPA. If submitting

a "collection of task orders" none of the six task orders shall be

submitted and counted as a separate Relevant Experience Project.

The RFP will be amended to reflect this.

Relevant Experience

Projects

Please confirm that the restriction to submit only one Relevant Experience Project

awarded in accordance with FAR Subpart 6.3, FAR subsection 8.405-6, or FAR

Subparagraph 16.505(b)(2) only refers to Relevant Experience Projects subject to the

FAR.

This restriction has been removed. Relevant Experience

Projects

Please confirm that the Government will accept local government projects as a

subcomponent of the U.S. state government category.

Yes, this will be considered a Non-Federal government Relevant

Experience Project.

Relevant Experience

Projects

Would the government please confirm our understanding of the following when

submitting non-federal Relevant Experience Projects:

1. Projects using Past Performance Substitute Form with a NAICS code identified:

Projects will count towards the minimum NAICS code requirement per Pool and will

be eligible to receive additional points if more than one NAICS code is submitted.

2. Projects using Self Certification Option: Projects will count towards the minimum

NAICS code requirement per Pool but will NOT be eligible to receive additional points

if more than one NAICS code is submitted.

1.Yes, Relevant Experience Projects that have their NAICS Code

determined by the Past Performance Substitute Form (J.6) as a

Pool NAICS Code will count towards the four required projects. The

scoring elements attached to Pool NAICS Codes have been

removed

2.Non-Federal Relevant Experience Projects with a self-certified

NAICS Code will also count towards the four required Pool NAICS

Code projects. An offeror may only self-certify the NAICS Code

when it is a Non-Federal government contract or task order and the

Past Performance Substitute Form (J.6) was not submitted.

Relevant Experience

Projects

When submitting verifiable contract documentation, can Offerors redact proprietary

client and company information so long as the objective evaluation factors are

apparent?

Yes Relevant Experience

Projects

Would it be helpful for HCaTS if Offerors are able to demonstrate prior support in

foreign countries? If so, we recommend adding the following evaluation criteria,

similar to what is used in the Alliant 2 Draft RFP:

L.XXXX Do any projects involve work in a Foreign Location? 50 2 50 100

No, the HCaTS PMO has determined that experience in foreign

countries does not increase the favorability of an Offeror since the

majority of HCaTS work is anticipated to be domestic.

Relevant Experience

Projects

81

Are past performances from the prime contractor of the proposed team, the only

contracts that can be referenced in the GSA HCaTS response?

The Government will not accept new teaming arrangements and

any proposal submitted under a new teaming arrangement shall be

rejected as non-conforming.

However, when submitting a proposal under an existing Joint

Venture, all Relevant Experience Projects and associated past

performance information shall have been awarded under the

existing Joint Venture's DUNS Number and not the individual

members making up the Joint Venture.

Relevant Experience

Projects

Can subcontractor past performances be submitted as one or more of the required

references?





considered a non-Federal government project. There is no

limitation on the number of Relevant Experience Projects that may

be submitted as a First Tier Subcontractors.

Relevant Experience

Projects

Are past performance references submitted by the team (both from the prime and the

subcontractor) required to be in the role as prime contractor on the reference

contract?









Relevant Experience

Projects

The solicitation indicates that each reference shall "have a value of no less than

$50,000." - is this an annual value or over the life of the contract?

The current minimum requirement refers to the total value.

We will revisit the minimum requirements of a Relevant Experience

Project.

Relevant Experience

Projects

REFERENCE: Unrestricted DRFP, Page 115 Section L.5.2, last paragraph on the

page

OFFEROR COMMENT/QUESTION: The solicitation states, “KSA(s) will be validated

by providing enough evidence within a contract or task order document, or other

verifiable contractual documents, to substantiate the scope of the project”. Is it the

Government’s intent to have only copies or extracts of contractual documents used

for validation and that there is no opportunity to provide written clarification or

explanation as would be seen in traditional past performance/experience citations?

The Offeror has the opportunity to explain how their Relevant

Experience Project is within scope of the KSA(s) that they are

claiming and then direct the Government to the supporting

contractual documents for substantiation in the Self-Score

Worksheet.

If the Government requires clarification in making a determination, it

will send out a clarification letter that will allow the Offeror to clarify.

Relevant Experience

Projects

82

REFERENCE: Section M.4.2.1 of the HCaTS Unrestricted DRFP states, “The

Offeror’s Relevant Experience Projects well be initially evaluated on a pass/fail basis

in regards to meeting the minimum proposal submission requirements in Section

L.5.2.” The fourth paragraph of Section L.5.2 states, “A Relevant Experience Project

is defined as a single contract; or, a single task order placed under a master Single

Award or Multiple Award Indefinite Delivery, Indefinite Quantity (SA/MA IDIQ) task

order contract (FAR Subsection 16.501-1); or, single task order placed under a

Federal Supply Schedule (FAR Subsection 8.405-2); or, a single task order placed

under a master Single Award or Multiple Award Blanket Purchase Agreement (SA/MA

BPA) (FAR Subsection 8.405-3 or FAR Subsection 13.303). In order for a single

contract and/or task order to be considered as a Relevant Experience Project, the

Contractor shall have provided a service(s) in accordance with the terms and

conditions of the single contract and/or task order. Single contracts and task orders

with no performance of a service(s) shall not be considered. If a single contract has a

task order(s) awarded against it, the Offeror shall submit either the single contract or

the task order(s) as the Relevant Experience Project, but not both. If the Offeror

submits the single contract and the task order(s) awarded against it, the single

contract and the task order(s) shall not be considered.”

QUESTION: Neither DRFP Sections M.4.2.1 or L.5.2 place any age restriction on an

Offeror’s Relevant Experience Projects. Is it the OPM and GSA intent to allow

Offeror’s to submit experience projects otherwise meeting all relevancy submission

requirements regardless of age?

The contract or task order must have been performed within 5

years of the solicitation closing, or be ongoing. This is stated in

section L.5.2.

Relevant Experience

Projects

In response to the Prime Contractor Experience comment posted April 9, 2015: If a

company is going to be a Prime Contractor on HCaTs and performed work as a

subcontractor on a contract with a Federal government entity, can this work be used

as Relevant Experience (i.e. prior subcontractor is now going to submit a bid as a

Prime and wants to use work they performed when they were a subcontractor as

Relevant Experience)?






Relevant Experience

Projects

Will the government allow submitting relevant experience qualifications from partner

organizations to support pool qualification?









Relevant Experience

Projects

Can you confirm whether work performed for a Federal Agency under a subcontract

with another firm will count as a US Federal Government project?






Relevant Experience

Projects

83

Please provide specific details of how a bidder can propose past performances

completed as a subcontractor






If submitting a project that was performed as a First-Tier

Subcontractor, the Offeror will have to submit verifiable

documentation that supports their claim (e.g., meeting a specific

KSA(s), period of performance, value, etc.). Offerors will have to

work with their Prime Contractor(s) to ensure the documents can be

released and included in their proposal.

Relevant Experience

Projects

When measuring the total duration of a contract, will recompeted contracts for

ostensibly the same work count towards the total duration? If the intent of awarding

extra points for long term performance of HCaTS relevant work is to reward

consistent performance over time, then work performed for the same customer for

extended durations (as evidenced by a SOW or other verifiable means) can

demonstrate the same qualifications as performance on a single contract. Given that

a vendor has no control over whether their customer contracts for one 5-year contract

or for five 1-year contracts, would the government consider allowing recompeted

contracts to be awarded the same points as contracts with a single term?

No, follow on contracts cannot be combined into one project and

submitted as a Relevant Experience Project. However, one

Relevant Experience Project may be a collection of six or less task

orders awarded under a master contract or BPA. If submitting a

"collection of task orders" none of the six task orders shall be



Relevant Experience

Projects

When measuring the total duration of an active contract, will the full period of

performance be evaluated or will only the completed portion of the contract be

considered.

Only the completed portion will be considered. Therefore, Offerors

shall not take credit for any period of performance after the RFP

closing date.

Relevant Experience

Projects

Would a contract with an entity that receives Federal funding be considered a US

Federal Government project/ Federal Customer?

No, an Offeror may only take credit for a Federal government

project if it was awarded a contract or task order by a Federal

agency.

Relevant Experience

Projects

The final CPARS reports for projects often only reference the period of performance

being evaluated (e.g. the final year of a multi-year contract) and as such do not reflect

the total contract duration or total value. How should offerors reflect the total period of

performance for the contract if the dates differ from those on the PPIRS or substitute

form?

The Offeror may use either the CPARS Report, PPIRS Report, J.6

Past Performance Substitute Form, FPDS-NG or a contractual

document to substantiate the period of the performance. The

period of performance shall be on what has already been

performed.

Relevant Experience

Projects

L.3, L.5.2 : In order to facilitate the evaluation process, recommend permitting the use

of excerpts, annotations, headers/footers, call out boxes, and other arrows on

verifiable contractual documents. This will enable evaluators to quickly see the

relevant information and tie it back to the scoring factors.


Experience Project is within scope of the KSA(s) that they are

claiming and then direct the Government to the supporting

contractual documents for substantiation in the Self-Score

Worksheet (Attachments J.5.1 and J.5.2).



Relevant Experience

Projects

84

L.5 Not allowing relevant project experience and past performance achieved as a

subcontractor, particularly while delivering services through the previous OPM-TMA

contract, will effectively eliminate from HCaTS competition many small businesses

with extensive experience providing the very services called for in this procurement.

DAI strongly recommends GSA and OPM allow the use of relevant project experience

and past performance as a subcontractor for the HCATS SB proposal submission,

and use the scoring system to differentiate the relevancy in terms of role, scope,

deliverables, results, value, etc.






Relevant Experience

Projects

Section L.5.2, paragraph 3, states, “For an Offeror to be eligible for consideration

under a given Pool, the Offeror shall have performed six Relevant Experience

Projects.” Page 116 of the same Section, paragraph 13, states, “If the Offeror is

applying for both Pools, they shall submit a minimum of ten and a maximum of twelve

Relevant Experience Projects.” Is there a maximum number of Relevant Experience

Projects for Offerors only competing for one Pool?

Yes, there is a firm number of six Relevant Experience Projects that

need to be submitted per Pool. If submitting for both Pools, there is

an allowed overlap of two Relevant Experience Projects that equals

to 10 unique Relevant Experience Projects, however, Offerors can

submit the full six Relevant Experience Projects if submitting for

both Pools to maximize the points.

Relevant Experience

Projects

RFI Question: OPM’s last answer states, “An Offeror can not submit a

subcontractor's past performance projects to meet the pool NAICS requirement. Nor

can they be used to meet the minimum number of Relevant Past Performance

Projects.” Can Offerors include past performance projects for their subcontractors if

the Offeror has already met the acceptability requirements with their own capes?

We are not sure what question you are referring to. Keep in mind

there have been many changes since the RFI.

Relevant Experience

Projects

L.5.2.3.4: Bundling of Task Orders under BPA/IDIQ. Will any bundling of task orders

under a single IDIQ or BPA be allowed when determined the project value of relevant

experience projects?






Relevant Experience

Projects

L.5.2.3.5: Relevant Experience Period of Performance. Many contracting offices we

work with issue only 12-month task orders. There are projects we have supported

consistently for over a decade, but a new task order is issued annually for the work.

Under the current scoring system, substantial benefit in the evaluation process is

given to contractors who happen to work with contracting offices who issue multiple

year contracts/task orders. We request GSA consider reducing the number of

additional points awarded to contractors for multi-year agreements as this can be

simply a matter of contracting office preference and not a key differentiator among

offerors.

There may be instances when a Relevant Experience Project's

duration exceeds 12, 36, or even 61 months; therefore, we want to

provide Offerors the opportunity to claim those points if they

successfully performed for that duration. Furthermore, there is a

trade-off from the Offeror's perspective that each project stands on

their own and the Offeror can use them towards the RFP's

minimum requirements.

Relevant Experience

Projects

85

L.5.2 para 5: We recommend removing the preference for federal past performance

credentials and counting corporate past performance credentials against the

requirement for a minimum number of NAICS-aligned credentials within each pool. To

address the fact that NAICS codes are not explicitly identified by client organizations

for corporate contracts, Offerors could submit an explanation of how a given

credential aligns to the NAICS code which it is considered to represent. Additionally,

Offerors could be required to format their corporate past performance credentials to

align to the format used in the Contractor Performance Assessment Reports System

(CPARS), allowing the government to perform a like-tolike comparison across all

credentials. Removing the bias against relevant corporate experience will allow for

fair consideration of Offerors who may possess institutional knowledge about private

sector organizations whose human capital and training effectiveness and efficiency

far exceed government norms. By considering corporate and federal experience on

equal terms, the HCaTS PMO can select Offerors who can bring public sector

experience and private sector innovation to Federal agencies.


amended.

Relevant Experience

Projects

Commercial Past Performance does not equate to innovation and Government Past

Performance does not equate to a lack of innovation; if GSA/OPM want to increase

innovation potential for HCaTs customers by awarding bonus points then bonus

points should be assigned to companies with relevant Industry Awards that tie to the

KSAs


amended.

Relevant Experience

Projects

L.5.3.2 Please clarify if an offeror can claim past performance for human

capital training modules that were developed for its own internal corporate

staff if they satisfy the relevant KSA 1, KSA2 or KSA3 criteria.

No, A Relevant Experience Project shall have been performed for a

customer outside the Offeror's corporate structure.

Relevant Experience

Projects

Section L.5.2 (page 119) requires that each Relevant Experience Project have a least

6 months of performance. We take pride in being able to complete our work for

Federal clients very efficiently, even with relatively large and complex efforts. This is

in fact one of our selling points to clients on why they should pick us rather than a

larger business. Please do not penalize companies like ours that complete work

quickly rather than letting client obstacles or vendor internal bureaucracy extend time

frames. We ask you either eliminate or reduce this requirement to something like 3 or

4 months.

We will revisit the minimum requirements of a Relevant Experience

Project.

Relevant Experience

Projects

J.5.2 The Relevant Experience Project Information outlined in Attachment J.5.2 states

only one Relevant Experience Project can be sole source. However, this requirement

is not included in the Draft RFP. Could the government clarify if

this is a requirement? If this is a requirement, what is the intent of the government to

limit Relevant Experience Projects to only one project that was awarded as a sole

source? If the intent of the government is to have vendors represent past

performance references that are of similar size and scope of HCaTS task orders and

to verify quality delivery, then the award type should not be used as a qualifier for

past performance references. This limiting factor places businesses that can receive

a sole source award (e.g., 8a, SDVOSB, HUBZone) at a disadvantage in the HCaTS

evaluation. Many agencies choose to award setaside business with a sole source

award due to the ease in which a contract can be awarded (and often times, there is a

competition prior to award despite how the contract is awarded)

This restriction will be removed in the RFP. Relevant Experience

Projects

86

There seems to be some potential ambiguity in section L.5.2, p. 114 about what can

be defined as a “project.” This definition seems to imply that a project could be

defined as either a single task order performed under a Multiple Award, Indefinite

Delivery, Indefinite Quantity contract, or the entire contract could be used as the unit

for Relevant Experience Projects (rather than a specific project under the IDIQ).

Under the OPM TMA vehicle, a single project may have numerous task orders, and

each task order may be small and specific to a unit of work. For example, a project to

design, develop, and implement a selection system for an agency may have separate

task orders for the management plan, job analysis, test development, implementation,

data analysis, and reporting. We would like to see greater clarity in terms of what

counts as a project for past performance purposes to ensure that we are allowed to

use a project, with multiple task orders, as a Relevant Experience Project.

The RFP will be amended to add additional language clarifying

what is a project.






Relevant Experience

Projects

In addition, the requirement that the project value be expressed as an annual value

can water down the evidence that a company can perform a large project within a

relatively brief period of time. For example, if a company performs $800,000 of work

for a client agency in the first year and $50,000 in each of 3 succeeding years on a

project, the annual value is only $237,500 and the scoring does not reflect the fact

that the company was able to perform nearly $1,000,000 of work in a 12-month

period. Is the average $237,500 per year really more valuable than $1,000,000 of

work in a single year? Your scoring implies that it is.

In order to evaluate proposals equitably, we have determined that

actual performance is the best methodology.

Relevant Experience

Projects

The DRFP provides no incentive for teaming because the past performance of

subcontractors is not considered. Given the requirements of the contract vehicle, we

would argue that their experience should count – otherwise it is likely we won’t be

competitive for this contract vehicle. If subcontractors’ experience does not count,

primes have no incentive to include smaller firms on their team that, while not a small

businesses, are not large enough to mount a credible HCaTS bid on their own.






A Relevant Experience Project will get points if they had three or

more subcontractors/teaming partners on the contract or task order.

We have reduced this threshold from the draft RFP from four to

three subcontractors/teaming partners based on industry feedback.

Relevant Experience

Projects

In section L.5, it states that, “All projects and past performance submitted in response

to this solicitation shall have been performed as a Prime Contractor,” and ”Any

evaluation element under Section L.5, Volume 1 through 5, for which an Offeror was

identified as a subcontractor shall be rejected.” Does this quoted information quotes

mean that our company may not use past performance for Pool Qualification Projects

and Relevant Experience Project(s) if we performed them as a subcontractor via

another contractor that was the Prime Contractor even though we performed a

majority of the work on the task order? If this is true, this seems to allow Prime

Contractors to take credit for work that was primarily done by subcontractors and fail

to allow Subcontractors to take credit for the work they actually did. We again believe

that the current RFP favors very large businesses and is biased against small and

medium-sized businesses.






Relevant Experience

Projects

87

M.4.3 Is the government’s intent to only evaluate past performance from potential

HCaTS prime contractors? Meaning, will the government consider past performance

from a potential HCaTS sub‐ contractor, that was performed as a prime?






Relevant Experience

Projects

L.5.2 The OPM TMA contract competed and awarded a top-level task order (0001) to

support a client based on proposals received in response to a Request for Task

Order Proposal (RFTOP). Subsequent to the top- level task order award, the work

was performed by the awardee as TMA projects, each of which could have multiple

task orders. For example, some TMA projects had more than 10 associated task

orders. These task orders, not the project, are individually

recorded in FPDS-NG. To demonstrate the full scope and magnitude of services

performed on a single RFTOP task order award, will the government allow an offeror

to aggregate associated projects and task orders into a single Relevant Experience

Project for evaluation?






Relevant Experience

Projects

L.5.2 The OPM TMA bridge contract allowed contractors to continue, and expand,

client project work started on the TMA contract. However, the continuation/expanded

work is recorded in FPDS-NG under the bridge contract

number. Will the government allow an offeror to aggregate associated client projects

and task orders from the TMA contract and bridge contract into a single Relevant

Experience Project for evaluation?






Relevant Experience

Projects

Will the government consider reducing the requirement from 6 to 4 past

performances for the Small Businesses set-aside?


amended.

Relevant Experience

Projects

Will the government consider reducing the minimum threshold dollar value for past

performances for the Small Business set-aside to 200K annually?

The minimum total value for each Relevant Experience Project is

$50,000.00. We will revisit the minimum requirements of a

Relevant Experience Project.

Relevant Experience

Projects

Will the government consider allowing more than one sole source past performance

reference for the Small Business set-aside?

This restriction will be removed in the RFP. Relevant Experience

Projects

Please reconsider the decision to determine in what KSAs contractors’ past

performance qualifies on the basis of contract paperwork only. Even if deliverables

are included as contract paperwork, this decision unfairly disadvantages contractors

whose projects were lightly documented, for whatever reason.

a. Furthermore, (see question 22 below), it isn’t clear whether the C.O. that

determines whether a project represents work in a KSA is the GSA/OPM evaluator or

the C.O. that actually oversaw the work being performed. The government official to

make this determination should be the COTR on the past performance. Additionally,

what level of documentation is necessary to establish the appropriate KSA for a

project?

The RFP will be amended allowing Offerors to submit contractual

deliverables in addition to contractual documents to substantiate

the claim of having performed a KSA(s).

Relevant Experience

Projects

88

L.5.2 Non-FAR-covered agencies have pre-approval/IDIQ type contracts similar to

FAR/GSA BPAs. For example, the FDIC issues “BOA” contracts, which are similar to

FAR BPAs in that competition is limited to BOA holders and rates are fixed at the

contract level. Will task orders under such arrangements be acceptable past

performance? If yes, can the RFP be clarified that this is permissible?

A Relevant Experience Project that was awarded by a Federal

agency (e.g., The Judiciary Branch), quasi-Federal agency (e.g.,

Federal Deposit Insurance Corporation (FDIC) and Federal

Reserve Bank), or semi-Federal agency (e.g., United States Post

Office) that does not award contract and task orders in full

accordance with the FAR shall not be considered a Federal

government Relevant Experience Project.

Relevant Experience

Projects

L.5.1.8 May work under contractor/US government joint venture arrangements be

submitted as past performance? A proposal may be submitted as a Joint Venture, all Relevant




Venture. An Offeror is prohibited from submitting a proposal

claiming a contract or task order as experience as either a Prime

Contractor or First-Tier Subcontractor if the contract or task order

was awarded to the existing Joint Venture that the Offeror was a

member of as a Relevant Experience Project.

Relevant Experience

Projects

M.7 Pool Past Performance (L.5.3.2.3) and Relevant Experience Projects (L.5.2.3.1

– L.5.3.4), may we add together follow-on contracts to the original contract, assuming

that the contracts are for the same tasks for the same customer?






Relevant Experience

Projects

L.5.3.2.1, would the Government allow use of subcontractor past performance for

Federal contracts that are more than a certain threshold? Perhaps $500,000?






Relevant Experience

Projects

L.5.3.2.2, M.7 While we agree that length of contract can be an indicator of

success, we have a concern regarding how the government will determine length of

contract.

OPM TMA has been the primary contract for procuring training and human capital

solutions over the past 25 years. However, due to recent changes in contract

requirements, every project is re-competed every year. Therefore, a successful

vendor may have worked on a project for 15 years, yet will only obtain the minimum

amount of points due to a contractual technicality. We suggest the government allow

vendors to submit previous task order contract documents as proof of length of

contract






Relevant Experience

Projects

Section L.5.2 (page 114) defines a past experience project as “a single contract; or, a

single task order under a master Single Award or Multiple Award, Indefinite Delivery,

Indefinite Quantity (SA/MA IDIQ) task order contract…” We request that the HCaTS

PMO consider modifying this definition to also include work performed under a single

OPM TMA project code or initiative. This will allow bidders to more fully represent the

diversity of KSAs, periods of performance, and contract values associated with their

relevant experience projects.






Relevant Experience

Projects

89

Section L.5.2 (Page 116) states, “Each Relevant Experience Project shall have at

least six months of performance, including options.” In addition to having a period of

performance that is at least six months long, can GSA please clarify if this also

means a project must have started at least six months prior to the due date for

proposals? For example, would a 12 month project which began four months prior to

the proposal due date qualify as a Relevant Experience Project?

In your example, the Offeror can only take credit for work performed

up to and including four months. Therefore, this project would not

count. However, we are revisiting the minimum requirements of a

Relevant Experience Project.

Relevant Experience

Projects

Sections J.5.1 and J.5.2 (Attachments J.5.1. and J.5.2, “Relevant Experience Project”

Tabs) includes the project attribute “Competed as Sole Source” and further states

that only one sole source project will be allowed. Since the method of competition is

beyond the offeror’s control and does not impact the type and level of quality of the

work performed, we strongly recommend that GSA consider removing this attribute

for all relevant experience projects.

This restriction will be removed from the RFP. Relevant Experience

Projects

Page 117, Section L.5.2, Volume II – “For an Offeror to be eligible for consideration

under a given Pool, the Offeror shall have performed six Relevant Experience

Projects, with four of those Relevant Experience Projects under a NAICS Code that

corresponds directly to a NAICS Code in the Pool being applied for.” Why is the

government making the past performance standard higher than in most federal

procurements? It is common to require 3 relevant experience, past performances.

For many small businesses, like ours, we have depth of experience, not the breadth.

We have about-6-7 ongoing contracts that we’ve held for six to 15 years. These past

performance projects, because of the length of experience performing them, are quite

comprehensive and span many key service areas. I find it troubling that the

government is focused on a number of past performances, rather than the quality and

scope of the relevant experience and past performance and the quality of

performance on those contracts. I would urge the government to reconsider requiring

6 past performances to possibly 3. Otherwise, you will knock out of competition

exceptionally performing small businesses that can perform work under both Pool 1

and Pool 2? We only have 6-7 past performances in total with a large scope and

have capabilities and experience in both Pool 1 and Pool 2 but we’d never be able to

meet the current past performance requirement in the Draft RFP.

Call Interested Party Relevant Experience

Projects

90

, Section L.5.2.3.1 Relevant Experience Projects for Federal Customers –

“For each Relevant Experience Project submitted, the Offeror will receive points if the

Relevant Experience Project was performed for a Federal customer. A Relevant

Experience Project is only considered Federal if the Offeror was the Prime

Contractor.” Why is there a requirement that the small business must be the prime

with respect to a relevant experience project? It is very common for a small business

to get work via a pass through. One of our largest and long running contracts of 15

years has us serving as the subcontractor doing 100% of the work. We didn’t have

access to the contract vehicle when the RFP was released but we are recognized

experts in the field of work and were brought on to do 100% of the work. Also, there

is a rampant trend in federal contracting to push contracts to the 8(a) program. This

past year, we were forced to take only 49% of the work we’d been performing as a

prime on for the 6-8 years prior because the acquisitions office put the work into the

8(a) program and we are not an 8(a) despite that we are a woman-owned small

business. I respectfully request that the government reconsider the requirement that

a small businesses relevant project experience only be as a prime. Again, if this

requirement stands, the government will disallow from competition very viable and

experienced small businesses with experience in both Pool 1 and 2.






Relevant Experience

Projects

Section L.5.2: “Only one Relevant Experience Project shall be submitted and

considered per Pool if awarded in accordance with FAR Subpart 6.3…”

- Please confirm that the contractor is only permitted to submit one set-aside

award (8a in this case) as a Relevant Experience Project.

This restriction will be removed from the RFP. Relevant Experience

Projects

The government states that it is only accepting Relevant Experience Projects and

their respective past performance from Prime Contractors and not Subcontractors.

Can you confirm that only Prime Offerors for this GSA HCaTS opportunity can submit

a past performance reference and not a subcontractor from the Prime’s team who

performed their selected reference in the prime role? Will the government consider

allowing subcontractors on the Prime’s team to submit past performance references if

the subcontractor performed as the prime for the selected reference?

If we cannot use our subcontractor’s past performance with our submission, can we

use their credentials to help boost our overall score according to the J.5.1 Self

Scoring Sheet? For instance, if one of our subcontractors has an ISO 9001:2008

certification or is CMMI Level 3, can we claim that on the scoring sheet?






Relevant Experience

Projects

91

Is an IDIQ or BPA with one or more task orders performed under it considered a

“single contract” that can be used as a single relevant past performance example? If

we can use an entire IDIQ/BPA as a single relevant past performance example, are

we allowed to roll up the contract value and period of performance to the IDIQ/BPA

level?

Offerors are permitted to submit as a Relevant Experience Project

a master contract if work was performed against the contract

without any task orders being issued (e.g., letter contracts). If a

task order was awarded against the contract, the Offeror can

submit either the contract or task order but not both. In other

words, if performance under a contract was only performed under a

task order, an Offeror cannot submit the contract as a Relevant

Experience Project. If a contract never had a task order issued

against it but the Offeror performed a service(s), the Offeror can

submit the contract as a Relevant Experience Project.

Relevant Experience

Projects

Will GSA confirm that we can submit more than one task order under an

IDIQ/FSS/BPA as relevant project experience examples?

Yes, multiple task orders can be submitted under one

IDIQ/FSS/BPA and count as separate Relevant Experience

Projects. Furthermore, one Relevant Experience Project may be a

collection of six or less task orders awarded under a master

contract or BPA. If submitting a "collection of task orders" none of

the six task orders shall be submitted and counted as a separate

Relevant Experience Project. The RFP will be amended to reflect

this.

Relevant Experience

Projects

Will GSA/OPM consider reducing the relevant experience project’s period of

performance from 6 months to 4 months? Many e-Learning projects have a duration

of fewer than 6 months.

Your recommendation will be considered. Relevant Experience

Projects

92

The terms of the solicitation unfairly limit competition for mid-size companies because

FPDS does not accurately report single IDIQ task orders.

Many IDIQ contracts split task orders into multiple contract actions when entered into

FPDS. For example, an OPM TMA task order may have been awarded as a single

task order and then appear as 13 different contract actions in FPDS. On the OASIS

contract, this was considered a “collection of task orders,” and companies were

limited to one collection of task orders per IDIQ. The impact is that companies using

work awarded under an IDIQ could be at a disadvantage depending on how the

Agency entered the contract actions. For example:

• If the language prohibits vendors from submitting more than one collection of

FPDS contract actions, then TMA vendors would only be able to use a single TMA

task order for past performance.

• Bonus points are given if a past performance is “greater than 13 months.” TMA

usually enters separate FPDS contract actions for each option years, so these entries

would seldom exceed 12 months, causing companies using a TMA task order to lose

out on up to 1,800 bonus points.

• Up to 2,400 points are given if the annual value of the past performance

exceeds $1M. However, if OPM decided to enter a $2M task order into FPDS as

three FPDS contract actions (which would be very common), then the vendor would

lose out on these points even if TMA originally awarded this as a single task order.

• Large companies have many, many more contracts to choose from than

companies in the $15M - $70M range and would not be adversely impacted by the

unreliable and arbitrary information in FPDS.


• Permit vendors to submit more than one collection of delivery orders as long as

they can provide documentation that the collection of delivery orders represents a

single task order award.






Relevant Experience

Projects

Given the broad scope of this contract and the wide variation in task orders issued

under the OPM TMA vehicle, would the government consider revising this

requirement to read at least ONE task order or a total estimated value of $25,000?

Q25. For example, would OPM consider awarding extra points for a

Masters or PhD in I/O Psyc

Relevant Experience

Projects

93

Example: FPDS-NG documents all contract actions under an individual award. In

many cases, both single award and IDIQ contracts are incrementally funded through

a series of multiple contract actions. The following is a sample report out of FPDS-

NG that shows how a single task order (identified by the Procurement Instrument

Identifier - PIID - field) can have multiple contract actions in FPDS-NG:

PIID Award/IDV Type Contracting Agency Date Signed Action

Obligation ($)

0001 Delivery Order Agency XYZ 20-AUG-2014 $100,000.00

0001 Delivery Order Agency XYZ 15-SEPT-2014 $150,000.00

0001 Delivery Order Agency XYZ 20-DEC-2014 $250,000.00

Total PIID 0001 $500,000.00

0002 Delivery Order Agency XYZ 03-MAR-2015 $1,234,000.00

0003 Delivery Order Agency XYZ 04-MAR-s015 $1,000,000.00

Total ALL $2,734,000.00

PIID 0001 is a task order and PIID 0002 is a modification of the task order issued

under PIID 0001. PIID 0003 is a separate task order unrelated to the first two task

orders.

In the example above, would the offer be allowed to submit PIID 0001 as a past

performance award with a total dollar value of $500,000.00?






Since PIID 0001 and 0002 are for the same task order, you can

take credit for all amounts associated with this task order.

Assuming that each action is a contratual obligation, the total

amount would be $1,734,000.00.

Relevant Experience

Projects

Would the offeror be permitted to submit a collection of task orders (PIID 0001 and

0002) as a past performance award with a total dollar value of $1,734,000.00 if

offeror can demonstrate that an error is made and that they are actually the same

task order?






Relevant Experience

Projects

If the offeror is permitted to aggregate PIID 0001 and 0002 because they are actually

the same project, would the offeror be permitted to submit PIID 0003 as a separate

past performance project?

Yes, only if PIID 0003 is a separate and distinct contract or task

order and meets the minimum requirements of a Relevant

Experience Project.

Relevant Experience

Projects

For relevant experience projects without ISR or SSR reports associated with them,

will the government allow firms to demonstrate small business participation with

invoices against contracts?

No, invoices will not be accepted to substantiate small business

participation.

Relevant Experience

Projects

Question: Does the government intend to offer the same instructions in terms of being

able to respond to any number of KSAs independently or will each vendor have to bid

on all 3 KSAs?

The RFP states that each Relevant Experience Project shall be

within scope of at least one KSA. Offerors are not required to

submit Relevant Experience Projects for more than one KSA.

However, those who do will earn additional points.

Relevant Experience

Projects

How does this approach impact the number of projects to be submitted by an offeror? There is no change to the minimum number of Relevant Experience

Projects that are to be submitted.

Relevant Experience

Projects

Page 140, Section M, the table indicates section L.5.3.2.3 for Pool Past Performance,

however, this section is not listed in the narrative. Please clarify.

The RFP will be amended correcting this. Relevant Past

Performance

94

Is it the Government’s intent to limit past performances only to the Prime?

Will teammates/subcontractors be allowed to submit their relevant past performances

that they have performed as a Prime?











Relevant Past

Performance

The suggested past performance period of performance is more in line with IT

Programs and not Human Capital Programs. Would the government consider

reducing the period of performance requirements to be in line with typical Human

Capital Programs? Most Human Capital Programs rarely exceed 36 months and

rarely if ever exceed 61 months.

There may be instances when a Relevant Experience Project's

duration exceeds 36, or even 61 months; therefore, we want to

provide Offerors the opportunity to claim those points if they

successfully performed for that duration.

Relevant Past

Performance

Section C.3.1.3, paragraph two, describes the scope of services included under KSA

3. Will work related to tool/system design or usability testing be appropriate under

KSA 3?

It depends on how the scope of the task order is written. Ordering

Contracting Officers have the ability to reach out to the HCaTS

PMO for assistance in making with-in scope determinations.

Scope

Section C.3.1.2, paragraph two, describes the scope of services included under KSA

2. Could the government provide more detailed information concerning the types of

work that are appropriate for KSA 2? For example, would the following service areas

be appropriate for this KSA: recruitment, pre-employment selection, job analysis,

competency modeling, job design, performance appraisal, organizational surveys,

test development and validation, and exit interviews? Do some of these service areas

fall under KSA 3? If so, which ones?

The types of work that were asked about for KSA 2 are within

scope. Some examples (but the scope of KSA 2 is not limited to

these) of the types of work that are appropriate for KSA 2 are: HR

strategy, Organizational and position management [includes job

analysis, competency modeling, job design], Staff acquisition

[includes recruitment, pre-employment selection, candidate testing

and assessment, and hiring], Performance management [includes

performance appraisal], Compensation management (excluding

payroll), HR Development, Employee relations.,Labor relations,

Separation management [includes exit interviews].

There may be an apparent overlap between some types of work

between KSA 2 and 3; the distinction is that KSA 3 should have the

objectives/outcomes stated for the effort in terms of organizational

performance improvement.

Scope

Section C.3.3, paragraph one, concerns IT and Non-Information Technology Products

and Services. Is it required that IT solutions have to meet all federal guidelines such

as 508 compliance and federal security requirements, or is this decided on a task-

order basis?

The RFP will be amended reflecting that Contractors shall comply

with Section 508 unless an exception applies.

Scope

95

L.5.2 The solicitation states, “KSA(s) will be validated by providing enough evidence

within a contract or task order document, or other verifiable contractual documents, to

substantiate the scope of the project”. Is it the Government’s intent to have only

copies or extracts of contractual documents used for validation and that there is no

opportunity to provide written clarification or explanation as would be seen in

traditional past performance/experience citations?


Experience Project is within scope of the KSA(s) and that it is

customizable that they are claiming and then direct the Government

to the supporting contractual documents for substantiation in the

Self-Score Worksheet (Attachments J.5.1 and J.5.2).



Scope

Recommendation 3: Include Human Capital and Training Subscription Services to

provide “Anything-as-a-Service (XaaS),” such as software-as-a-service, platform-as-a

service, infrastructure-as-a-service or other human capital and training subscription-

based services as part of HCaTS. The subscription service must be paired with, and

used to enable, a service offered by an Offeror in FC1 or FC2; or the subscription

supports one or more human capital or training

KSAs, or the Federal HR Line of Business enterprise service architecture. This will

allow contractors to offer innovative XaaS solutions. The government benefits

through avoiding capital expenditures, and by accessing solutions that delivers a best-

value impact. Today in the commercial human capital and training space XaaS is how

commercial customers are solving their complex human capital needs. The market for

subscription services will dramatically increase over time because it represents an

easy, cost effective way to procure reoccurring services. Adding XaaS to HCaTS will

accommodate rapid innovations in process and technology and make HCaTS more

attractive to government buyers, especially shared services providers that want to

rapidly scale offerings

The RFP prescribes services that are explicitly out of scope. It is

not practical to identify every possible service that can be within

scope of HCaTS because of the nature of the acquisition (i.e.,

HCaTS is a Governmentwide contract solution). However,

Ordering Contracting Officers can reach out the HCaTS PMO for

within scope determinations.

Scope

Recommendation 4: Add a KSA for Information Technology Support of Human

Resource Systems. The RFI included a KSA for IT Support of HR Systems. IT

supporting HR systems is an ongoing client need and should be included in HCaTS

scope to fully meet agencies’ needs. A challenge on the current TMA IDIQ is that IT

and systems supporting human capital and training requirements are not specifically

described or called out. This results in a large “greyarea” where agencies, OPM, and

contractors are unclear what IT services are in/out of scope. We recommend the

government add IT Support of HR Systems as a separate KSA, or include it as part of

the current 3 KSA descriptions, to make it clear to all parties what IT is in and out of

HCaTS scope.


amended.

Scope

96

C.1.1 The RFI included a KSA for IT Support of HR Systems. IT supporting HR

systems is an ongoing client need and should be included in HCaTS scope to fully

meet agencies’ needs. Will the government consider adding this KSA back in?

Justification/Reason/Explanation: A challenge on the current TMA IDIQ is that IT and

systems supporting human capital and training requirements are not specifically

described or called out. This results in a large “grey area” where agencies, OPM, and

contractors are unclear as to what IT services are in/out of scope. We strongly

recommend the government include IT in either a separate KSA, or include it as part

of the current 3 KSA descriptions, to make it clear to all parties what IT is in and out

of scope on the HCaTS contract. Specifically, we recommend the inclusion of

systems requirements, vendor or technology selection support, cloud services

implementation or migration, and technical integration across the multiple HR and

Training systems that agencies may have in place.

No. KSAs 4 & 5 were determined to be ancillary services that can

be provided under KSAs 1, 2 and/or 3.

Scope

C.3.1.1/2/3 Could the government please elaborate on what is and is not in scope in

terms of temporary services and IT products and services? How will the ordering CO

define and document ancillary and incidental? “As a part of an integrated and total

solution, temporary services as defined by FAR Section 37.112 and information

technology products and services are allowable provided they are ancillary and

incidental to the in-scope work to be performed” Justification/Reason/Explanation: As

previously stated, a current challenge many customers experience on TMA today is

the ambiguity and lack of clarity around what IT is in and out of scope. We believe

clearly calling out what pecifically is in scope and out of scope will help address this

challenge.

The RFP prescribes services that are explicitly out of scope. It is

not practical to identify every possible service that can be within

scope of HCaTS because of the nature of the acquisition (i.e.,

HCaTS is a Governmentwide contract solution). However,

Ordering Contracting Officers can reach out the HCaTS PMO for

within scope determinations.

Scope

L.5.2.2 Is the Contracting Officer referred to in this section the GSA/OPM evaluator?

In other words, this section provides for the GSA/OPM evaluator to determine when a

project represents one or more KSA based on the contract paperwork, not the

Contracting Officer for the project that is being offered as evidence of work in a KSA?

The Contracting Officer referred to in L.5.2.2 is the GSA

Contracting Officer that will be awarding the contracts under

HCaTS. The Offeror will submit their explanation on how a

Relevant Experience Project is within scope of the KSA they are

claiming credit for and submit supporting documentation that the

GSA Contracting Officer will use in making their determination.

Scope

L.5.2.3.2 Please confirm that the “verifiable contract documents” to be submitted in

support of a multiple KSA assertion include any document approved by the

government under the contract or during acquisition, such as project deliverables and

RFPs.

Yes, Offerors are permitted to submit contractual deliverables to

substantiate their experience under a KSA(s).

Scope

L.5.3.2.3 Until recently, under the OPM TMA contract, modifications were allowed

so the scope of projects kept changing but the SOWs were never updated.

Therefore, vendors who performed under the OPM TMA contract may be at a

disadvantage if SOWs are the only means of documenting the accomplishment of

KSAs. We suggest the government allow the submission of Management Plans,

emails, deliverables, etc. in order to substantiate KSA accomplishment.

The RFP will be amended to allow deliverables and all contractual

documents to substantiate the scope of a Relevant Experience

Project.

Scope

97

Do Not Allow IT or HR Staff Augmentation Projects to be Used as Relevant

Experience. Draft RFP Sections C.3.3 and C.3.4 addressing IT services and

temporary support services both note that these are considered “ancillary services”

and may be provided only as part of total integrated solution. Thus, such services

should be “incidental to the work to be performed.” Consistent with this restriction,

GSA should specifically and explicitly prohibit offerors from using past performances

whose primary purpose was providing IT services or HR temporary support services.

Allowing such projects as relevant experience would be inconsistent with restricting

such services to a minor and supporting role in task orders issued under the HCaTS

vehicle. Furthermore, allowing IT projects as relevant experience will distort the

competitive framework as large IT projects generally have a duration and cost far

larger than “pure” human capital or training projects and would unfairly provide a

scoring advantage to firms for relevant experience that, in fact, would not be allowed

under the contract. Therefore, GSA should require that offeror certifies that each

relevant experience included in its proposal involved less than 50% IT and less than

50% temporary HR support services, as measured by funded contract value.

In order for a Relevant Experience Project to be considered, the

project has to be customized and within the scope of one of the

three KSAs. We will consider amending the RFP to reflect your

consideration.

Scope

Page 14, Section C.3.1. and Page 51, Section H.4.1 – It is still unclear how the KSAs

relate to the pools. There are three KSAs but only 2 pools. What is tie-in between

the KSAs and Pools?

The Pools are a grouping of NAICS Codes of the same size

standard so the Government knows the business size of the

Offeror. Both Pools are inclusive of Section C and the three KSAs.

Scope

In the Key Services Area (KSA) "developing effective metrics to assess progress in

carrying out human capital strategies," are there currently any analytical systems in

place or desired technology preferences the government has to carry out this

function?

Because this is a Governmentwide acquisition, there may be but we

are unaware as to what they are. Those types of requirements will

be identified in the task order solicitations.

Scope

Information Technology

Under the previous Training Management and Assistance (TMA) contract there was a

lack of clarity about whether IT could be purchased as part of a solution under the

contract. Under the HCaTS contract moving forward, it is important that both

customer agencies and contractors are clear as to what IT is within the scope of

HCaTS and what is not. We recommend that GSA make this clarification within the

KSA descriptions, and include a definition of IT and the permissible scope in the final

solicitation. It would also be helpful to include language that specifically addresses

ancillary support as allowable costs that may be included within an individual task

order under the HCaTS contract.

IT can be purchased as a total solution so long that it is not the

primary purpose. The language in the RFP provides Ordering

Contracting Officers with the flexibility to meet their requirements.

In addition, Ordering Contracting Officers are encouraged to work

with the HCaTS PMO in

Scope

L.5.3.2.3 – Key Service Areas: How will the Government verify if a relevant

experience project is within the scope of a stated KSA?

The Offeror will provide the rationale for the Relevant Experience

Project both being within scope of the KSA(s) applied for and that it

is customizable along with the references for the substantiating

documents in the Self Scoring Worksheet (J.5.1 and J.5.2). The

Government will substantiate the information provided by Offerors

in the contractual documents referrred to by the Offeror in the Self

Scoring Worksheet. Offerors need to provide enough information

so the Government can validate the claim.

Scope

98

Section C, pg 12:

With no requirement for offerors to submit a technical approach, how will the

government measure an organization’s current ability to support the KSAs according

to the principles and objectives identified on pages 12 and 13?

The Offeror will provide the rationale for the Relevant Experience

Project both being within scope of the KSA(s) applied for and that it

is customizable along with the references for the substantiating

documents in the Self Scoring Worksheet (J.5.1 and J.5.2). The

Government will substantiate the information provided by Offerors

in the contractual documents referrred to by the Offeror in the Self

Scoring Worksheet. Offerors need to provide enough information

so the Government can validate the claim.

Scope

Section C.3.3, pg. 19, paragraph 4: “The OCO shall ensure that the aggregate dollar

amount of all ancillary support services and supplies, including IT and non-IT

products and services, is less than 50% of the task order’s awarded amount or

estimated cost. OCOs may establish further restrictions to this threshold; however,

are prohibited from exceeding it at any time.”

. Is software development included in the government’s definition of non- IT?

Is enterprise system development included in the government’s definition of non- IT?

Yes to both scenarios. Scope

This section of the draft RFP states, “Annual project value for ongoing projects is

determined as follows: total estimated value (inclusive of all option periods) divided by

the total number of months of performance (inclusive of all option periods) multiplied

by 12.” Is the same formula applied to determining the number of months in a period

of performance? Thus, the number of months in a period of performance for an

ongoing project is inclusive of executed months plus the future option periods?

No future months will be counted towards a Relevant Experience

Project's period of performance.

Scoring

This section of the draft RFP states that the offeror will receive maximum points if the

period of performance meets or exceeds a period of performance is equal to or

greater than 61 months, including options. Given that the majority of contracting

offices award contracts for a base period with four options, with additional periods

awarded for unusual circumstances, can 60 month contracts qualify for maximum

points? If not, will the government consider maximum points for contracts over 60

months?

As written, an Offeror will get the maximum amount of points for a

Relevant Experience Project that has a total duration equal to or

greater than 61 months.

We will revisit the allocation of points for each scoring element.

Scoring

There are no scoring points listed with each level of certification (ICCM and CPCM) in

the table for L.5.4.14. What are the scoring points associated with each level of

certification?




Scoring

The points in the table add to 23,800 for pool 1, and 24,000 for pool 2. The final rows

in the table show 24,800 total points for Pool 1 and 26,800 total points for Pool 2.

Please verify each scoring element and the total points for each pool.

The Final RFP will reflect the correct scoring elements Scoring

Page 126, Section L.5.3.3 says Relevant Experience Projects will receive additional

points if the offeror meets or exceeds its small business contracting goals. Since

small businesses must be the prime, won’t all such projects automatically qualify? Or,

does this section only apply to large businesses?

This scoring element will be removed from HCaTS SB RFP. Scoring

99

The solicitation states that "Only in the event PPIRS information is not available will

an offeror be allowed to substitute a past performance substitute form in accordance

with Section L.5.3.3" - may we please clarify where past performance substitution is

addressed in Section L.5.3.3 - Meeting or Exceeding Total Small Business Goals.

Neither the PPIRS nor the Past Performance Substitute Form will

be used to substantiate the scoring element; meeting or exceeding

total small business goals. The Offeror will submit their eSRS

report to demonstrate that they met or exceeded their total small

business goals.

All citations will be corrected in the RFP.

Scoring

Under the OASIS procurement on which HCaTS is being modeled, the government

provided a minimum cut score that Offerors need to obtain to receive a contract

award. Will the government provide the cut score for HCaTS prior to submission?

Establishing a cut score prior to submission allows potential bidders to evaluate their

chances of obtaining an award, reducing the cost to bid for companies who the

Government would not consider viable participants in the HCaTS contract. The cut

score provides the additional benefit of reducing the number of offers that must be

evaluated, speeding up the time to award.

We are not providing a minimum score that an Offeror must

achieve to be eligible for award. If an Offeror achieves all of the

minimum requirements then they are considered eligible for an

award. We cannot determine the score that will lead to an award

and therefore providing a minimum score would not lead to a

potential Offeror knowing their chances of receiving an award.

Scoring

L.5.2.3.5 Scoring based on the length of a contract is an arbitrary indicator of quality

training work since the length is set by the government according to their acquisition

strategy. This is particularly true for IDIQ contracts, where duration of the IDIQ may

have no relationship to any particular task order duration. Offerors could get duration

credit for a single, large value, task order with a short duration by claiming the total

IDIQ contract duration. Recommend that duration be removed from the scoring

criteria. If the HCaTS team feels scoring should be differentiated based on contract

length, we suggest that the maximum duration for additional points is 36 months or

more, rather than the current “greater than 61 months.” With the Relevant

Experience Projects limited to performance within the past 5 years (i.e., 60 months),

giving additional credit to project in excess of 61 months does not appear logical.


amended.

Scoring

L.5.3.3 Many government contracts do not require socioeconomic performance

goals. Recommend eliminating or reducing the number of cites (e.g., a maximum of 2

Relevant Experience Projects can claim credit for exceeding goals) that require

ISR/SSR/eSRS reports.

This scoring element is not mandatory and an Offeror may claim

this for every Relevant Experience Project.

Scoring

L.5.3.3: Meeting or Exceeding Small Business Goals. Please clarify the applicability

of section L.5.3.3 to the small business solicitation.

The HCaTS SB contract vehicle will be amended to remove this

scoring element.

Scoring

M.7 HCaTS is intended to be a government wide contract. Consequently, it makes

sense that offerors with a demonstrated ability to deliver HCaTs services to broader

areas of the Federal Government are more likely to be effective contributing members

of the the HCaTS program. Therefore, to add a meaningful business development

discriminator to the scoring process would GSA consider giving additional points to

offerors who can demonstrate that they have provided training services to multiple

sets of various Departments? The precedent for this is the OASIS contract where

offerors gained more points for demonstrated service to more predetermined

segments (MIssion Areas) of the Federal Space. See the GSA OASIS solicitation

sections L.5.3.3.1 and M.5.1.10 for an effective methodology.


amended.

Scoring

100

M.7 HCaTs is a multiple award IDIQ (MA-IDIQ) contract. Consequently, it makes

sense that offerors with a demonstrated ability to successfully manage multiple award

contracts are more likely to be effective contributing members of the the HCaTS

program. Therefore, to add a meaningful operations discriminator to the scoring

process would GSA consider giving addtional points to offerors who can demonstrate

that they have successfully managed MA-IDIQ contracts? The precedent for this is

the OASIS contract where offerors gained more points for demonstrated task order

awards across multiple MA-IDIQs. See the GSA OASIS solicitation sections L.5.3.3.2

and M.5.1.11 for an effective methodology.


amended.

Scoring

Do not award bonus points for systems required by CAS covered businesses. You

can still collect for informational purposes. Otherwise there is no way for companies

who don’t currently have systems to receive bonus points.

We will revisit the allocation of points for each scoring element. Scoring

Work with OPM to carefully identify directly relevant criteria and remove rating

elements such as these that don’t assess the ability of a firm to provide innovative

Human Capital and Training solutions.


Commercial work is viewed as less valuable than work performed for the government.

Explanation – many vendors work with similar issues in the private sector and many

best practices originate in the private sector. Private sector/ commercial past

performance should be evaluated on the merits of the project and the ratings

provided by the client and at no penalty or lower scale than work performed for the

Federal Government.

We believe that administering a federal project, on the whole, is

more difficult than a non-federal project; however, we will revisit the

allocation of points for each scoring element.

Scoring

L.5.2.3.4 and L.5.2.3.5 For each of these sections, points are awarded for projects

that meet or exceed different tiers as far as either annual value or period of

performance is concerned. Are the different periods of performance worth more or

less points? (Ex. Is a project that lasted >6 months, but <37 months worth more or

less than a project that lasted =or> than 37 months, but < 61 months?). The same

question regarding Annual Value.

Section M presribes additional points for projects with higher values

and periods of performance.

Scoring

We do not agree with awarding more points for projects larger in size and scope, or

that involve four or more subcontractors. Giving more evaluation points to larger,

more complex projects adds bias that favors large companies. If points are awarded

to past performance projects, we would prefer to see them awarded for quality-related

indicators (i.e., client satisfaction scores in PPIRS above a certain threshold) rather

than for indicators that reflect the project’s size and scope.


amended.

Scoring

In section L.5.2.3.3 Relevant Experience Projects with Pool NAICS Codes, the ability

to receive additional points that increase with the number of additional validated Pool

NAICS Codes is another factor that creates a bias in favor of the largest businesses.

There may be excellent small or medium-sized businesses that have focused

strength in one or two areas that may be a better value for performing work for an

agency than a larger business that has a workforce spread across multiple areas of

business.

This scoring element will be removed. Scoring

101

The scoring sheet in M.7 clearly favors the largest businesses in giving so many

additional points to projects that involve more than one KSA or that have very high

annual dollar values. In our view, for the Unrestricted pools, this requirement is

biased in favor of very large companies that have a greater capacity to serve as

prime contractors on complex, multifaceted projects with scopes that naturally cut

across multiple KSAs. As a small, non-profit organization, most if not all of our past

performance examples conducted through the current OPM TMA vehicle focus on a

single KSA, as defined here, so we would be hard pressed to cite past performance

that would allow us to obtain these additional points


In section L.5.2.3.6 (pp. 120-121) you state that you will add points if a Relevant

Experience Project involves Subcontracting/Teaming with at least four separate and

distinct entities. As we note above, we do not think this should be an evaluation factor

because it is biased in favor of large companies, who typically prime the type of large

projects that require sizeable contractor teams. As currently worded, does the number

four include one’s own organization (the prime) or is it one’s own organization plus

four additional entities? The choice of four entities seems arbitrary.

Based on industry feedback, this scoring element has been

reduced to give points for a Relevant Experience Project that has

three or more subcontractors/teaming partners. The three or more

subcontractors/teaming partners are not inclusive of the Offeror

who would have been the Prime subcontractor on this contract or

task order.

Scoring

Recommendation 1: Remove NAICS codes from pool qualification requirements, and

do not award additional points for NAICS, as the codes are only used for classifying,

collecting, analyzing, and publishing statistical data related to the U.S. business

economy. The government should evaluate projects based on the relevance of the

type and quality of the services provided. Further, using NAICS codes as a pool

qualification requirement may restrict highly qualified offerors from bidding or

presenting their most relevant projects for evaluation. For example, work performed

under the current OPM TMA bridge contract is reported in FPDS under NAICS

511210, which is not associated with either HCaTS pool. Eliminating NAICS codes for

pool qualification and evaluation will allow offerors to submit their most relevant

projects and for evaluation by the government.

This scoring element will be removed from the RFP. Scoring

L.5.2 Based on the Relevant Experience Projects requested, nowhere does an

offeror demonstrate experience managing large MAC/IDIQs of this nature. Will the

government consider adding “Relevant Experience (Secondary) Projects with Multiple

Award Contracts/BPAs and Task Orders” so an offeror will receive additional points

for Multiple Award Contracts/BPAs and corresponding task orders of the HCaTS

nature. Justification/Reason/Explanation: By doing this the government will know that

an offeror has the experience to manage and promote a contract of this nature that

will be used across all Federal government agencies


amended.

Scoring

Section L.5.2.3.6 Relevant Experience Project with Subcontracting/Teaming – Would

the government consider reducing the number of separate and distinct entities

required to receive points for relevant experience? OR would the government

consider removing this section?



three or more subcontractors/teaming partners.

Scoring

102

On page 144, section L.5.2.3.1, would the Government consider providing points for:

“project was performed for a Federal customer” and separate/additional points for

“The Offeror was the Prime Contractor.”






Additional points will be earned for projects performed as a Prime

Contractor under a Federal government contract and/or task order.

Furthermore, additional points will be earned for projects performed

as a First-Tier Subcontractor for a Prime Contractor's Federal

government contract and/or task order, albeit less than the points

allocated for Prime Contractor's experience under a Federal

government contract and/or task order.

Scoring

On page 144, section L.5.3.2.1, Line 1 – is it the Government’s intent to provide

points if the total value of the project is greater than $250,000; and then additional

points for the respective annual values listed under Line 1?

No, the Offeror may only receive points at one tier level per scoring

element. The Relevant Experience Project will get the points based

on the highest tier level that their annual value hits.

Scoring

Regarding L.5.3.4 in the self-scoring worksheet that pertains to small business

participation goals, will the government consider eliminating this as part of the scoring

criteria?

We believe that the question is referring to the scoring element for

meeting or exceeding subcontracting goals on the Small Bussiness

Contract Vehicle. This scoring element will be removed from the

HCaTS SB RFP.

Scoring

Regarding L.5.2.3.6 in the self-scoring worksheet, will the government consider

decreasing the number of subcontracting or teaming arrangements for small business

primes from 4 separate distinct entities, to 2 separate and distinct entities?




Scoring

103

Recommendation 2: Add Management of IDIQs as an Evaluation Factor

Measuring a company’s ability to manage IDIQ contracts and win task orders reduces

the risk of awarding to a company that may be poorly qualified to administer a large

IDIQ contract and drive new work to it. It would also provide additional differentiation

by evaluating the experience and performance a company has in managing IDIQ

contracts, in addition to just executing task orders. Managing an IDIQ requires

different capabilities than those associated with managing a single contract and GSA

schedules, which are sometimes equated to an IDIQ contract given the fact that

multiple task orders can be awarded on a schedule. However, the execution and the

management of a GSA schedule is not the same as that of a large IDIQ contract such

as HCaTS. We are not recommending that IDIQ experience replace past

performance experience; rather, we believe an additional scoring factor associated

with the management of IDIQ contracts would provide an important and reliable

predictor of future quality performance. We also believe it is an equally objective yet

much more effective discriminator for IDIQ management than counting the number of

certifications that Key Personnel hold.

By GSA’s own account, there are more than 1,600 IDIQs across the Government. For

this factor, we do not believe the scope of an IDIQ changes the ability of offerors to

manage the IDIQ. Therefore, we recommend that GSA and OPM add an evaluation

factor that is based on the experience and success a prime contract holder has

demonstrated on IDIQ contracts. As was done on OASIS, additional points could be

given based on the number of IDIQs a company holds and the number of Task

Orders performed. We recommend that a scoring model similar to OASIS be used.

Below is the OASIS scoring model used to evaluate a company’s ability not only to

successfully manage IDIQs, but to drive work to IDIQ contracts – which is a key

element of making an IDIQ successful.

Within Last 5 Years:

• Prime holder of 2 IDIQs with at least 10 total task orders and at least 3 task

orders on each —50 points

• Prime holder of 5 IDIQs with at least 25 total task orders and at least 3 task

orders on each —100 points


amended.

Scoring

104

Recommendation 3: Adjust the Scoring Criteria and Point Values for the Length of

Task Order/Contracts

Points are allocated for the length of a task order. For nearly all Government single

award contracts and task orders for services, the maximum period of performance is

five years. In addition, most contracts involving training or human capital type

services typically last no longer than three years. The current proposed scoring is:

• 13 months but less than 37 months– 100 points

• 37 months but less than 61 months -200 points

• 61 months or greater - 300 points

We suggest that the scoring criteria and point value be adjusted to:

• 13 months but less than 15 months – 50 points

• 15 months but less than 25 months – 100 points

• 25 months but less than 37 months – 150

• 37 months or greater – 200 points

We recommend adjusting this scoring methodology for two reasons. First the period

of performance is not a true measure or discriminator for the complexity of, or the

impact and value that task order has on the client’s mission. For example, providing

half a dozen full time instructors for a five year period, we believe, does not deserve

significantly more points for a project that involves a two year highly complex

reorganizational design and implementation.

Second, due to the nature of this work, the current fidelity regarding the period of

performance (number of months) does not allow for real discrimination. We believe

the majority of all projects will fall within 13-37 months. Under the current scoring

methodology a project will usually obtain 100 points, with a few receiving 200 points.

Thus, there will be very little differentiation for this evaluation factor among the

bidders.


Please reconsider the decision to award more points for contracts with higher dollar

value. Higher dollar value is not indicative of quality performance, nor is it clear, from

GSA’s statements to industry, that the HCaTS vehicle will be reserved only for

contracts of higher value.


Please reconsider the decision to award more points for contracts of longer duration.

Length of contract is not indicative of quality performance, nor is it clear, from GSA’s

statements to industry, that the HCaTS vehicle will be reserved only for long

contracts.


Please reconsider the decision to award offerors points for small business

subcontracting only for having achieved goals on a small business plan. We feel this

unfairly discriminates against companies that have not been required to file a small

business plan, having been small on all contracts until recently. Companies should

be allowed to show a commitment to small business contracting in other ways, such

as FFATA documentation of actual awards to small businesses.


105

Please reconsider the decision to award extra points for estimating systems,

purchasing systems, and forward pricing rates approved by the appropriate

government agency. This unfairly discriminates against contractors that have not met

regulatory threshholds or been awarded contracts of types that allowed for such

government reviews.


The RFP indicates that “if the error rates exceeds 10% the Offeror shall be excluded

from further consideration for award.” Given the potential for a disconnect on KSAs

applicable to projects, will the Agency consider abandoning this provision? It creates

the risk of an arbitrary elimination from the competition based upon a good faith

difference of opinion.

This exclusion has been removed. The Government may ask

clarifying questions based on the initital proposal submitted to

further our understanding of a specific element. However, Offerors

will not be permitted to revise their proposals.

Scoring

Will the Government add an evaluation factor in M.7 for assessing what the

Government defines as success at the IDIQ level for vendor provided customized

training and development services, human capital strategy services, and

organizational performance improvement services (i.e., successfully managing high

volumes of several relevant contracts) and make appropriate reductions to the point

values for evaluation criteria having less relevance to success?


amended.

Scoring

M.7; B.1.1 [5 U.S.C. 1304 (e)(1)]; B.1.2; B.1.3 Discussion. In the December 22,

2014, “HCaTs Update” posted on GSA Interact Blog, GSA stated that, “…the HCaTS

program is the cornerstone of the new Human Capital category, part of OFPP’s

Category Management initiative…we are working to develop the HCaTS contract

solution, enabling Federal agencies to acquire complex and tailored human capital,

workforce support, and other training solutions within the context of the Human

Capital Assessment and Accountability Framework (HCAAF).” If it is the

Government’s intention to identify a small number of prime contractors that will be

responsible for assisting all Federal agencies in carrying out the tasks required under

the HCAAF, then it would seem logical that these prime contractors demonstrate a

specialization in and corporate commitment to HR/HCM professional services.

Suggestion. Create one or more new scoring elements that measure the level of

corporate commitment potential prime contractors have to the HR/HCM professional

service offerings intended to be combined under the HCaTS Category Management

Hallway. There are several ways of doing this including considering the percentage

of corporate revenue that comes from Government or commercial HR/HCM

contracts. OPM/GSA could also consider the total revenue amount, number of

Federal customers, and/or total number of awards received in this area over the past

5 years. All of these potential measures reflect not just the corporate commitment, ut

the level of specialization in HR/HCM professional services.


amended.

Scoring

L.5.3.2.1, M.7 The words “on an annual basis” are limiting and seem contrary to

what OPM would want. For example, a 12-month, $1M project will score 400 points

whereas a 13-month, $1M project will only 200 points.

The emphasis of awarding points in this section should be on size alone and not

combined with length of contract. We suggest the government remove the words

“on an annual basis” from this section.



Scoring

106

L.5.3.2.1, M.7 Training and human capital projects, unlike IT projects, tend to be

shorter in duration and smaller in scope.

While we agree that size of project can be an indicator of capability, the majority of

training and human capital projects are under $250,000. First, we suggest, as

mentioned above, the government remove the words “on an annual basis” from this

section. Second, we suggest the government lower the dollar threshold for the

assignment of points to accurately reflect the nature of this work. Points should only

be given for projects greater than $250,000.



We will revisit the current Relevant Experience Project minimum

requirements.

Scoring

L.5.3.2.5. M.7 We are not sure how this section benefits the government. It seems

to reward companies who can’t do the work themselves and have to subcontract to

more qualified companies. Awarding up to 1200 for subcontracting out the work

seems excessive and contrary to what the government would want. We suggest the

government remove the points associated with this item.


L.5.3.4 Most, if not all of the projects we will be submitting as past performance, had

small business goals at the contract or IDIQ level, not at the project level.

Therefore, assigning evaluation points for meeting project-level small goals is unfair.

We suggest the government remove the points associated with this item or allow

vendors to submit documentation of contract or IDIQ level small business goal

achievement.


Section L.5.2.3.6 (Page 121) states that offerors will receive additional points for each

Relevant Experience Project submitted that “involves Subcontracting/Teaming for

services with at least four separate and distinct entities.” While management of

multiple subcontractors may be viewed as an element of project complexity, this

metric rewards firms for subcontracting significant portions of work due to a lack of

breadth and depth of human capital and training experience. Will GSA consider

revising this section to provide additional points for Relevant Experience involving

“Subcontracting/Teaming for services with at least one separate and distinct entity?”




Scoring

Section L.5.1.6 (Page 104) stresses the Government’s commitment to small business

contracting and a desire for large-business Contractors to creatively involve small

businesses during performance of the HCaTS contract. Given this focus, would the

Government consider the establishment of small business teaming partners as a

scoring component of the solicitation evaluations. Specifically, would the government

consider adding an additional scoring element including specific additional points that

can be awarded for establishing teaming arrangements with small businesses across

various small business designations (e.g., HUBZone, WOSB, VOSB, SDVOSB,

etc.)?

The RFP currently allows for Offerors to claim for additional points

Relevant Experience Projects for teaming/subcontracting.

Scoring

Page 122 and 123, Sections L.5.2.3.4 and L.5.2.3.5 – What is the objective in

assigning points for the dollar value and length of term of a Contractor’s relevant

project experience? Wouldn’t a contractor’s performance on a contract be more

important?

Yes, both experience and past performance are more important

than dollar value and length. We will revisit the allocation of points

for each scoring element.

Scoring

107

Subcontracting—The DRFP awards points for past performance involving

subcontracting/teaming with four or more separate or distinct entities. The evaluation

of demonstrated experience managing 4 subcontractors puts those companies that

can offer 7 agencies a total solution at a disadvantage. For HCaTS type work, it is

unclear why the ability to manage multiple subcontractors would be preferable to the

ability to offer a total solution. Therefore we suggest that this criteria be removed.

As all other than small business concerns will be required to have

an approved subcontracting plan in order to receive a contract

award, we want to recognize those Offerors who have successfully

done so in the past. In addition, we anticipate Offerors having to

form teaming arrangements at the task order level and want to

recognize those Offerors who have successfully done so in the

past. However, we have lowered the number from four to three.

Scoring

L.5.3.4 – Small Business Goals: This section indicates that additional points will be

given if a project exceeds small business goals. For task orders issued under an IDIQ

contract, small business goals are set at the IDIQ level and not the task order level.

When citing a task order award, are small business goals considered to be met if the

offeror has met the small business goals of the IDIQ?

Yes, as per the RFP "If a subcontracting plan does not exist for an

individual Relevant Experience Project, the ISR or SF 294 report

associated to the Relevant Experience Project under a

subcontracting plan at the master contract level shall be submitted."

Scoring

L.5.3.2.2 – Period of Performance: This section indicates that additional points will be

given based on the period of performance for relevant experience projects. Do the

terms of 13, 37 and 61 months include phase-in period?

The period of performance for each Relevant Experience Project

shall commence from the effective date of the contract or task

order. In the event that you performed work prior to the official

effective date, you cannot take credit for this work.

Scoring

L.5.3.2.2 – Period of Performance: This section indicates that additional points will be

given based on the period of performance for relevant experience projects. The

ranges for point values are measured in months. When converted to years, it appears

that the thresholds are whole years plus one month. Is it the intent of the government

that the period of performance include a phase-in period?

The period of performance for each Relevant Experience Project

shall commence from the effective date of the contract or task

order. In the event that you performed work prior to the official

effective date, you cannot take credit for this work.

Scoring

Comment: With the continued importance of fiscal responsibility and the pressure to

do more with less, cost competition on task orders is a key element in the success of

multiple award IDIQ contract vehicles.

Recommendation: The Government may consider the addition of a scoring element

for offerors’ proven success on IDIQ contracts of similar scope. Possible elements

might include IDIQ response rates and awards over the previous five (5) years.


amended.

Scoring

Comment: In section B.2.3 – Cost Reimbursement Task Orders, the draft RFP states

that cost reimbursement task orders will only be used of non-commercial items.

Additionally, based on historical experience working on multiple award IDIQ contracts,

it is highly unusual for task orders to be cost reimbursement type contract.

Recommendation: Because the majority of task order awards are likely to be firm

fixed price, we recommend removing the scoring element for cost-type contracts

and/or replacing it with a scoring element for fixed-price type experience, as that more

accurately represents the likelihood of prime contractor success on HCaTS.


amended.

Scoring

Page 122 of the RFP: L.5.3.3 Meeting or Exceeding Total Small Business Goals / Will

the government remove this instruction as under the SB set aside RFP?

The HCaTS SB contract vehicle will be amended to remove this

scoring element.

Scoring

108

of the RFP: L.5.3.2.6 Relevant Experience with Subcontracting/Teaming

“For each Relevant Experience Project submitted, the Offeror will receive points if the

Relevant Experience Project involves Subcontracting/ Teaming for services with at

least four separate and distinct entities.” Would the government consider reducing the

number of subcontractors on each relevant experience project from four to two as this

would show that the prime can manage subcontractors, but still has the capability to

perform the majority of the work?




Scoring

Would the government consider awarding points to Offerors who have won and have

experience managing a competitively awarded MAIDIQ?

Your recommendation was considered but the RFP will not be

amended.

Scoring

The solicitation favors large firms with complex back office systems over firms that

demonstrate HC expertise.

The solicitation limits the opportunity for the government to access innovative, cost-

competitive solutions because it discriminates against mid-size companies in the

$15M - $70M range, especially as regards accreditation for systems with DCAA

audits, as well as CMMI and ISSO compliance. Mid-size companies have significant

expertise as demonstrated by their success on the TMA vehicle, but lack the complex

back office systems of the very large firms. An example of the big firm advantage is

the requirement for DCAA audited systems, which are triggered by both the type

(Cost Plus) and the size of the contract awards (Purchasing and Estimating systems

must audited at $50M award level per D-FAR, although can be audited at any size).

Examples of how the solicitation benefits very large companies over mid-size

companies with HC expertise:

• Companies receive four times as many points for CMMI/ISO9001 certifications

(600 points) as they do for having staff with Human Resources Certifications (max

150 points)

• 1,500 combined points for having DCMA audited systems & an EVMS

• 1,800 points are automatic for large firms and mid-size firms may not be able to

meet contract size bonus levels: 600 points max value for 6 projects under $500K,

2,400 points max value for 6 projects over $1M.

• Some of the systems and certifications required by Draft Section L may not be

necessary or relevant for the predominance of the work that will be performed under

HCaTS. For example, it is rare that an Estimating System, Purchasing System, or

Earned Value Management System would be needed under HCaTS or even be

relevant to it.

• GSA has not released the Industry Day list for HCaTS, but assuming it is similar

to OPM CHRS, 78% of the 259 contractors at the CHRS Industry Day do not appear

on the DCAA Active Contractor list. Given the high number of points allocated to

DCAA audited vendors (1500), this gives a significant advantage to a small number

of companies who happen to have large DoD cost-plus contracts.

• By awarding such a large number of bonus points for DCAA audited systems

(more than a company could receive for additional KPIs), HCaTS clearly provides an

advantage for a small set of the largest federal contractors at the expense of

HCaTS Team will revisit the allocation of points for each scoring

element.

Scoring

109

Section L.5.3.3.3, pg. 122 and Section L.5.3.4, pg. 141. There are 600 points for

meeting total small business subcontracting goals. For any relevant experience

project that does not have an ISR or SSR, meeting or exceeding small business goals

shall not be considered.

Some contracts do not require specific goals (including the previous TMA contract,

which didn’t have small business requirements for our firm, which is classified as

large on the vehicle), so companies could end up being scored zero for this even if

they subcontracted significant work to small businesses.

For relevant experience projects that do not have small business goals, will the

government accept small business goals at a corporate level based on approved

GSA schedule small business plans as a proxy for contract-specific small business

goals?

In order to validate an Offeror's claim that they met the

subcontracting goals for a previously approved subcontracting plan,

we will only accept an ISR or SSR for that Relevant Experience

Project.

However, an Offeror can substantiate their claim that they have

teamed or subcontracted with at least three other entities with

invoices, assuming that we can validate the relationship with the

Offeror and the entities for that specific project can receive points

under that scoring element.

HCaTS team will revisit the allocation of points for each scoring

element.

Scoring

Why are points awarded if the relevant experience project is inclusive of cost

reimbursement (but not T&M)?

Time-and-Materials contracts do not have the same requirements

and require the same level of oversight that cost reimbursement

contracts require on the part of the Contractor.

Scoring

Since past performance and relevant experience seem to be the most important

factors for HCATS, is it possible that it can carry more weight/points to the overall

scoring system? The current portion of total points for this category is about 30% of

the total possible points. We recommend it be much higher and at least 50%,

because this is the most important factor for end users and for success under HCATS

The HCaTS team will revisit the allocation of points for each

scoring element.

Scoring

Offerors should be evaluated on their ability to build strong teams of companies--

regardless of the size status of individual team members--that can deliver the desired

capabilities. As such, GSA and OPM should refrain from giving extra evaluation

points based on the number of small businesses included in the offer and their

socioeconomic status. It is counterintuitive that under the HCaTS Draft RFP a prime

contractor that builds a strong team comprised of the best mid-tier and small

businesses may receive fewer evaluation points than a prime contractor that only

includes small businesses on their team.

The RFP currently allocates points for Offerors that have performed

projects with other teammembers.






task order.

Scoring

L.5.2.3.6 Due to the nature of the work that will be performed on HCaTS and the

elimination of Pool 3, we recommend that the government lower the threshold for

receiving additional points for teaming/subcontracting from four (4) separate and

distinct entities to two (2), as two entities is a more representative and realistic

estimation of the prime/subcontractor relationships for the size, scope and complexity

of Human Capital and Training contracts.






task order.

Scoring

110

We recommend reducing the weight of this evaluation criteria to 25 points each as

follows:

Section Element Point Value Number of Potential Occurrences

Total Max Points Per Element Total Max Possible Points

L.5.3.2.6 The project is inclusive of Cost-Reimbursement. 25 2 50

50

Most vehicles that specialize in Human Capital and Training services, such as OPM

TMA and other GSA schedules, do not provide for cost-reimbursable contract types,

this evaluation criteria is restrictive to Human Capital and Training companies whose

contracts are primarily procured under those vehicles, while providing unwarranted

advantage to vendors that only perform these services as ancillary functions to their

core capabilities which require cost reimbursable contracts.

The HCaTS team will revisit the allocation of points for each

scoring element.

Scoring

L.5.3.2.1, M.7 Training and human capital projects, unlike IT projects, tend to be

shorter in duration and smaller in scope. While we agree that size of project can be

an indicator of capability, the majority of training and human capital projects are under

$250,000.

Comments/Suggestions: Suggest the government remove the words “on an annual

basis” from this section.

Second, we suggest the government lower the dollar threshold for the assignment of

points to accurately reflect the nature of this work. Points should only be given for

projects greater than $250,000.

HCaTS team will revisit the tier break down of this scoring element. Scoring

Will there be an assigning different weighting or point scores based on scope and

performance differences between prime contracts generally and First-Tier

subcontracts?

HCaTS team is contemplating allocating additional points for

Relevant Experience Projects performed by First-Tier

Subcontractors, but not as much as Relevant Experience Projects

performed by Prime Contractors.

Scoring

Is there now placing equal weight on First-Tier subcontracts and commercial prime

contracts?

HCaTS Team is contemplating allocating additional points for

Relevant Experience Projects performed by First-Tier

Subcontractors, but not as much as Relevant Experience Projects

performed by Prime Contractors.

Scoring

Under which SB Pool does the government anticipate acquiring training

development? If the answer is SB Pool 1, the government will be accepting significant

risk. Very few small businesses under the $11M size standard will have the

experience, necessary and appropriate staff to produce interactive multimedia

instruction (IMI) which is SCORM compliant. Most small businesses producing web-

based IMI fall in the $15M to $27M size standards. NAICS Code 611430,

Professional and Management Development Training is not for training development.

Careful review of this code reveals that it is for delivering training for professional and

management development. This type of training is frequently delivered by a single

training consultant. The $11M size standard is appropriate for this type of activity but

very restrictive when the government is trying to acquire complex, sophisticated web-

based IMI.

Training development fits under both Pools since they have

identical scopes that are defined by all three Key Service Areas

(KSAs). Training development fits under KSA 1 Customized

Training and Development Services. As the KSAs define the

complete scope of HCaTS and HCaTS SB, there may be some

parts of the eight NAICS Codes' definitions that are not within

scope.

Task Orders will be issued under the Pool that contains the

predominant NAICS Code for that task order.

Size Standard

111

· In order to meet the qualifications for a Small Business, will the Prime offeror

need to qualify as a Small Business at the time of Proposal Submission or at the time

of contract award?

o Based upon the current estimated timeline, the time between proposal submission

and contract award could exceed 6 months. This extended period of time could affect

the status of a company.

In accordance with FAR 19.301-1 Representation by the offeror.

(a) To be eligible for award as a small business, an offeror must

represent in good faith that it is a small business at the time of its

written representation. An offeror may represent that it is a small

business concern in connection with a specific solicitation if it meets

the definition of a small business concern applicable to the

solicitation and has not been determined by the Small Business

Administration (SBA) to be other than a small business.

Therefore, Offerors shall represent their business size in good faith

at time of proposal submission.

Size Standard

Please reference: Draft RFP Page 84 “Pool 2: Size Standard $15M”. How are the

size standard of $15M defined? Are they defined by the three year average of

receipts or revenue or another method? Please clarify.

The methodology to calculate your business size can be found in

FAR Section 19.101.

Size Standard

How will the Government verify the size standard of the Offeror when applying for a

specific Pool(s)?

Determinations will be based on the Offeror's SAM record. Size Standard

Page 119 of the RFP: Pool 2 $15M Size Standard Table- NAICS Codes / Would the

government consider adding 541614 (Process, Physical Distribution, and Logistics

Consulting Services) as a NAICS Code under Pool 2, as it is the same $15M size

standard and is often used for similar services, to include training and human

resources, as well as, those under KSA 3- pertaining to process improvement?


amended.

Size Standard

Section H.3.1, Set Asides Based on Socio-Economic Group. Is there a reason why

socio-economic set asides are designated using a “rule of 3” (the presence of at least

3 responsible Contractors within the socio-economic category), whereas the usual

Government practice is to apply the “rule of 2” (the presence of at least 2 responsible

Contractors to fulfill the requirement)? Conformance to the standard practice of “the

rule of 2” seems to make more sense to ensure HCaTS SB is aligned with existing

Federal regulations for Contract Officers.

To ensure that the Rule of 2 from the FAR may be achieved, we

are ensuring that there will always be at least two contractors that

are able to respond.

Socio-economic

Section B.1.7, Minimum Guarantee and Maximum Ceiling. Please note that the SBA-

mandated ceiling on awards to 8(a) certified small companies is $4 million. We

recommend OPM/GSA confer with the Small Business Administration about the rules

governing this maximum ceiling amount to ensure HCaTS SB is in alignment with

these SBA regulations

The ceiling on awards to an 8(A) Certified Small Businnes only

applies to sole source awards. The HCaTS contracts are being

awarded competitively and therefore this ceiling does not apply at

the contract level. Ordering Contracting Officers awarding sole

source task orders to HCaTS contractors will have to be in

compliance of this ceiling as well as all other regulations.

Socio-economic

In reference to the set-aside rule "for a specific socio-economic group when it is

anticipated that offers will be obtained from at least three responsible small business

concerns within a specific socio-economic group under the corresponding NAICS

Pool?" Are there exemptions to this considering the Federal government's universal

"rule of two" regulation as it pertains to HUBZone companies?

To ensure that the Rule of 2 from the FAR may be achieved, we

are ensuring that there will always be at least two contractors that

are able to respond.

Socio-economic

112

Will the government please clarify how Offerors should estimate the total dollars to be

subcontracted?

The total subcontracting dollars is the amount that your company

believes that it will subcontract out in a year if it was to be awarded

a contract (for an Individual Subcontracting Plan). This is an

Offeror's business decision.

Subcontracting Plan

Section L.5.1.6.1, paragraph four, states, “Demonstrate that its subcontracting plan

represents a creative and innovative program for involving small, HUBZone small,

small disadvantaged, women-owned, veteran-owned, and service-disabled veteran

owned small business concerns in performing the contract.” How is “creative and

innovative” being defined? Will there be criteria to define creativity and innovation?

Each subcontracting plan is unique and will be evaluated based on

its own merits. Each subcontracting plan will be reviewed by the

Office of Small Business Utilization (OSBU) and SBA, which will

make recommendations to the HCaTS Contracting Officer, who

may enter into discussion with the Offeror to address any concerns.

Subcontracting Plan

In the table on p. 106, section L.5.1.6 Subcontracting Plan, we assume that the small

business goal of 50% for the government is higher than the level the government

expects Contractors competing for the unrestricted HCaTS contract to use in their

subcontracting plans. Otherwise, the cost of competing for and administering the

contract would seem to be too high relative to what the Prime Contractor will get out

of the contract.

Each subcontracting plan is unique and will be evaluated based on

its own merits. Each subcontracting plan will be reviewed by the

Office of Small Business Utilization (OSBU) and SBA, which will

make recommendations to the HCaTS Contracting Officer, who

may enter into discussion with the Offeror to address any concerns.

Subcontracting Plan

L.5.16 Is there still an expectation of a 50% small business subcontracting goal on

the Unrestricted solicitation even though there is a separate SB-set aside award?

Yes. All other than small business concerns shall submit a

subcontracting plan in accordance with 52.219-9.

Subcontracting Plan

G.3.3 Does the reference to plural Individual Subcontracting Plans mean that

ordering activities can require subcontracting plans on task orders?

No, G.3.3 refers solely to the requirement for a Subcontracting Plan

at the contract level.

Subcontracting Plan

Which entity will receive credit for small business awards, GSA, OPM, or the

ordering agency?

The Ordering agencies will receive credit for the subcontracted

dollars.

Subcontracting Plan

Section A.2 suggests any project exceeding $650,000 has to include a plan to involve

small, HUB zone small, small disadvantaged, women-owned, veteran-owned, and

service-disabled veteran owned small business concerns. However, the nature of the

work may prohibit subcontracting due to lack of expertise or it may increase risk and

cost to the government. We suggest contractors be held to contract-level

subcontracting goals and not at the task order level.

All other than small business concerns shall have an approved

subcontracting plan incorporated in the contract.

Subcontracting Plan

Section G.3.3, Subcontracting Plan. The verbiage in paragraph #2 is a bit unclear.

We recommend revising this paragraph to make it clear that submission of SF 294

Report and Summary Subcontract Reports (SSR) is voluntary for those HCaTS SB

participants that have voluntarily submitted Subcontracting Plans, and not a

mandatory requirement for all HCaTS SB participants.

The RFP will be amended to reflect your recommendation. Subcontracting Plan

In reference to the requirements in Section L.5.3.3 for meeting small business goals,

are we allowed to use a subcontracting report at the contract level for IDIQs (such as

OPM-TMA), BPAs, and Federal Supply Schedules (such as GSA MOBIS)?

Yes, as per the RFP "If a subcontracting plan does not exist for an

individual Relevant Experience Project, the Individual

Subcontracting Report (ISR) or SF 294 report associated to the

Relevant Experience Project under a subcontracting plan at the

master contract level shall be submitted."

Subcontracting Plan

113

The solicitation discriminates against companies that have not been on contracts

with small business plan requirements EVEN IF the offeror has given significant work

to small businesses.

There are 600 points for meeting total small business subcontracting goals. Some

contracts do not require specific goals (including the previous TMA contract), so

companies could end up being scored zero for this even if they subcontracted work to

small businesses.


• Accept small business plans at a corporate level based on GSA schedule small

business plans.

• Allow firms to demonstrate small business participation with invoices against

contracts versus government forms

In order to validate an Offeror's claim that they met the

subcontracting goals for a previously approved subcontracting plan,

we will only accept an ISR or SSR for that Relevant Experience

Project.

However, an Offeror can substantiate their claim that they have

teamed or subcontracted with at least three other entities with

invoices, assuming that we can validate the relationship with the

Offeror and the entities for that specific project can receive points

under that scoring element.

Subcontracting Plan

Beyond the overall small business subcontract plan required at contract formation,

specific subcontracting goal requirements should be negotiated at the time of task

order competitions and subcontracting plan compliance should be evaluated on a

task order by task order basis. It is only at that level, when specific requirements are

known, that truly effective and relevant subcontracting plans can be created.

In accordance with FAR 19.702, "Any contractor receiving a

contract for more than the simplified acquisition threshold must

agree in the contract that small business, veteran-owned small

business, service-disabled veteran-owned small business,

HUBZone small business, small disadvantaged business, and

women-owned small business concerns will have the maximum

practicable opportunity to participate in contract performance

consistent with its efficient performance." Therefore, a

subcontracting plan must be agreed to at the contract level.

Subcontracting Plan

Contractor subcontract plan compliance should be recorded on a task order by task

order basis, could be an evaluation factor in the source selection for future task order

awards, and should be a factor when evaluating whether to “off-ramp” HCaTS

contract holders.

An Offeror's subcontracting reports will be reviewed and

noncompliance is grounds for off-ramping.

Subcontracting Plan

The draft RFP states, "all projects and past performance submitted in response to

this solicitation shall have been performed as a Prime Contractor.” Does this

preclude a small business from utilizing a subcontractors past performance in order to

qualify for the opportunity?






Subcontractors

Section L.5.2.3.6 says that additional points will be given for teaming with 4 or more

entities. Do 1099 personnel count as subcontractors?

No, 1099 personnel do not count as subcontractors. This

requirement has been amended to allow points for 3 or more

subcontractors.

Subcontractors

114

Even if subcontractors’ qualifications cannot be used to fulfill that requirement, will

the Government still consider subcontractor’s experience and expertise as part of the

overall team’s capabilities in evaluating the proposal?












Subcontractors

Please confirm that it is acceptable for offerors to pursue an HCATS prime contract

award themselves and also be included as a subcontractor on another Prime’s offer.

Yes, a company may submit a proposal even if a company that they

have worked for as a subcontractor is also submitting a

proposal.An Offeror's subcontractors are not part of their proposal.

Subcontractors

115

• Allow relevant experience from the Prime offeror or an exclusive teammate. X

interprets Section L.3.1 of the draft RFP, Official Legal Entity, as allowing only the

experience and other qualifications of the offeror for evaluation purposes, much like

the OASIS procurement. Hence, the qualifications of any teammates/subcontractors

could not be used or counted for evaluation. X believes that this approach is both

unnecessary and detrimental to GSA’s and OPM’s stated intent to have the best

qualified providers under the HCaTS vehicle. As industry has plainly stated in

numerous fora and would be easily confirmed by market research, no single company

has the breadth and depth of expertise to fully meet the full suite of services that fall

under the banner of human capital or training. For example, in the service area of

human capital, compensation analysis and labor relations management are two

important but highly specialized fields for which the best providers are niche players

with deep but narrow expertise in these fields. To get the best providers able to

provide the full suite of either human capital or training services will require a team of

contractors and GSA, OPM, and their government customers would benefit from

those teams being assembled prior to contract award and evaluated based on the

collective qualifications of the team. Hence, X recommends that GSA change the

RFP to allow an offeror to include the relevant experience of a subcontractor,

provided that the majority of relevant experience cited is from the prime itself.

Further, X believes that this approach only makes sense with the restriction that such

experience may be used only if the subcontractor is exclusive as a subcontractor to

that offeror AND not bidding as a Prime in that portion of the competition. In other

words, a large business could be a (exclusive) teammate to a Prime in both the small

business competition and the full and open competition but not submit a proposal as

a Prime. Similarly, a small business could be an (exclusive) teammate to another

business in the full and open competition and submit a prime proposal in the small

business portion but not in the full and open. This restriction will prevent certain

companies with compelling relevant experience from using that to bolster the

competitive position of multiple offerors and thereby distorting the competition away

from a sufficiently large and diverse set of awardees.






However, when submitting a proposal as a Joint Venture or

Contracting Teaming Arrangement (CTA), all Relevant Experience

Projects and associated past performance information shall have

been awarded under the existing Joint Venture's DUNS Number

and not the individual members making up the Joint Venture or

CTA. A member of the CTA or Joint Venture may not use a contract

or task order awarded to the CTA or Joint Venture on their

individual proposal.

Subcontractors

116

RFP Section L.4, Proposal Format. The RFP states, “The Offeror’s proposal shall be

formatted into one zip file, if possible, with each volume composed as a separate

folder within the zip file. If the proposal does not fit in one 25MB zip file, then the

Offeror shall create more than one zip file so long as each zip file contains a full

volume of the proposal. A volume shall not be split into multiple zip files.” Comment:

Based on our experience preparing our proposal for OASIS, we believe that it is likely

that Volume II will exceed the 25MB threshold, even after the files are compressed

into ZIP files. The number of scanned pages necessary to substantiate bidders’

asserts regarding their relevant experience projects—which could number as many

as 12 projects if bidding both pools—will likely exceed that limit. We recommend that

GSA permit Offerors to split a volume into multiple clearly named ZIP files if

necessary due to file size constraints. Alternatively, GSA could choose to change the

delivery approach from email to delivery of a CD or DVD, which would eliminate file

size issues related to proposal transmission.



this change.

Submission

RFP Section L.4.1, Proposal Format Table; L.5.2.2, Scoring for the Relevant

Experience Projects; L.5.2.3,

Points for Relevant Experience Projects. Question: Does GSA anticipate that, like in

the OASIS procurement, one of the mandatory forms will enable Offerors to provide a

small amount of text (e.g., 200 words) to explain how the provided contractual

documentation substantiates each of the scoring elements? While preparing our

OASIS proposal, we found that it wasn’t always immediately obvious how the

contractual documents substantiating our assertions. We believe that in the case of

OASIS, Offerors’ ability to provide a very short explanation of the documents

provided and what they showed probably made it easier for the Government to

validate Offerors’ self-scores. We recommend that GSA take a similar approach in

HCaTS, especially to substantiate individual or multiple KSAs associated with a

project.

Yes, the Self-Scoring Sheet (Attachments J.5.1 and J.5.2) has a

space for the Offeror to explain how the Relevant Experience

Project is within scope of the KSA(s) that the Offeror is claiming.

The Offeror will also have to list the supporting contractual

documents that demonstrate the scope of the project and state

where the Government should look to find this information. It is

recommended that the relevant sections be highlighted and the

Offeror will just need to state the page numbers and state that the

areas that are highlighted demonstrate the scope.

Submission

11. Page 140, please clarify appropriate volume numbers in the table. The Final RFP will have the appropriate volume numbers identified. Submission

After issuing notice on or about May 19th, what is the estimated time the response

due date due to the large volume of information to compile and transmit.

The Government will provide no less than 30 days. In the event

that additional time is needed the RFPs can be amended to allow it.

Submission

L.4. Is there a desired naming convention for the zip file or files containing the entire

proposal as there is for the individual files identified in L.4.1?



this change. The zip files or folders shall be named according to

Volume number.

Submission

Section L.4, Proposal Format. The transmission of proposal financial data and other

sensitive information via unencrypted emailed files seems risky from a cybersecurity

standpoint. Allowing proposal files to be password protected and/or encrypted to

prevent unauthorized access by external parties (read: by hackers and

cybercriminals) seems prudent. We recommend allowing the submission of password

protected and/or encrypted files, if email is to be the only form of electronic proposal

submission allowed. Zip files can be password protected.

The RFP will be amended requiring all documents to be

downloaded onto a DVD+R. Offerors will be allowed to password

protect the files and the RFP will be amended.

Submission

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Due to technical problems, GSA has been unable to include some contracts in eSRS.

Will the government accept paper versions of ISR/SF 294 or SSR/SF 295 if they

have been submitted to GSA but are not available in eSRS?


downloaded onto a DVD+R.

Submission

Will the government accept paper versions of ISR/SF 294 or SSR/SF 295 if the

offeror can demonstrate that GSA has been unable to include our contract in eSRS?


downloaded onto a DVD+R.

Submission

Section G.2.4, paragraph three, line item five, states, “Allowing a reasonable time for

fair opportunity proposal submission.” Can the government provide an estimate of a

typical turnaround time for responses to a task order proposal? How will the

government determine which of the IDIQ winners are selected to bid on individual

task orders?

The acquisition strategy, evaluation methodology and award criteria

are determined by the Ordering Contracting Officer based upon the

specific requirements of that acquisition. Since so many different

requirements can be awarded at any time throughout the fiscal year

from any Federal agency, it is difficult to come up with a typical

turnaround time.

Task Order

Section G.3.2.1, paragraph one, line item 14, states, “Contract Type for each CLIN.”

Is it possible that there could be different CLINs within the same task order that are

different contract types?

Yes, that is a possibility. Task Order

Section G.4, concerns task order closeouts. Will there be guidelines concerning the

minimum or maximum amount of time upon completion of the work that a task order

must be closed out?

The FAR and agency supplements prescribe when a task order is

to be closed out.

Task Order

H.19: Reduce the Minimum Task Order Award Requirement. GSA establishes a

minimum of three task order awards or a total task order estimated value of $1 million

prior to the first option year being executed under HCaTS SB. We appreciate the

importance of each prime being active in the competitive process, but view this as a

very aggressive minimum assuming there are approximately 40 primes in each Pool

and both the small and unrestricted HCaTS contracts. We encourage GSA to closely

review the task order pipeline to ensure this minimal award requirement is realistic.




Task Order

H.4.2. Does the reference to “set aside” task orders mean that ordering agencies can

set-aside task orders on the unrestricted HCaTS contract or does it refer to an order

made against the small business HCaTS contract?

An Ordering Contracting Officer will be permitted to set aside a task

order in accordance with the FAR and agency supplements.

Task Order

Reference: B.2.3 COST , last sentence, “Cost Reimbursement task orders shall only

be used for the acquisition of non-commercial items.” Question: What is an example

of a non-commercial (a) training and development service, (b) human capital

strategy service, and (c) organizational performance improvement service?

The determination whether or not an acquisition meets the

definition of commericiality is with the discretion of the Ordering

Contracting Officer.

Task Order

Section B.3 (Page 9) notes that HCaTS ceiling rates that are in effect at the time of a

task order award shall remain with the task order award during the entire term of the

task order, including task orders with options. We interpret this to mean that rates

proposed on task orders may be escalated, but that future changes to the HCaTS

ceiling rates will not affect escalated rates on task orders that have already been

awarded. Can GSA please confirm that task order rates may be escalated consistent

with the HCaTS ceiling rates in effect at the time a task order is awarded?

Yes, if the task order solicitation permits escalation rates for future

years, this methodology is permitted.

Task Order

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